All recent comments on applications from ACT Planning & Land Authority, ACT

On a preliminary note: I wrote a comment in support of this proposal a week ago that does not appear here on the public comments. I am concerned certain comments by others may have also been lost. I repeat some of my earlier comments here.

I support the development of this block of land into medium density accommodation for social housing purposes. Although I am not an expert in design, from what I can the housing appears to remain within the footprint of the current under utilised space.

I live a short walk from Bill Pye park and my children have played in it regularly over the years. It is a loved space by the community. Adding essential housing to our community is welcomed and in my view will not detract from the amenity of the park and will increase public use and enjoyment of the green spaces.

The need to create pockets of medium density housing while retaining critical green space is key to creating a sustainable and socially diverse community. This small area with its close access to the Ainslie shops and proximity to green space seems ideal for the small group of homes proposed. It is particularly welcome in light of the large scale sell off of public housing currently happening in Ainslie and surrounding suburbs. This proposal is a small and yet sustainable contribution to broader housing mix in our neighbourhood and is welcomed.

I am not an expert on design but hope that the buildings are appropriately sustainable and energy efficient with easy disability access.

Fully supportive of providing housing for disadvantaged older women, especially centrally located. The building should be sustainable and the esthetic should match the environment and surrounds, so as to enhance the lives of both the residents and the neighbours.

I support this important housing development on a block of land owned by YWCA Canberra.
Having followed the first tribunal hearing, a bit more honesty from those who oppose the development, is their primary motivation for opposing this development is the socio economic status of those who will live there, which became apparent at the ACAT hearing when one of the objectors, in his evidence, said the following:
“…we've got to be careful that there's not a, in a sense, an over concentration
of people on low income or a particular age…” (transcript, Page 92 lines 11-12)
“I think if - one of the problems that - that might occur from the development is
a skewing towards people who essentially are living in poverty and there
might be over - it might end up being over 50 per cent of the - the actual 25
people in the street” (transcript, Page 92 lines 22-26).

Thank you for the opportunity to show support from this much needed development, as an Inner North Resident, we need to maintain the right to have access to live in our beautiful inner suburbs, regardless of your socio economic status.

ACAT decisions and the importance of due process

There were a number of reasons that the ACT Administrative Tribunal (ACAT) found was wrong with the proposal at ten units with most caused by the high density of the development on such a constrained site. The reasons for ACAT’s disapproval of the development.

The key issues found were:
• inadequate parking;
• poor solar access;
• Inadequate personal open space;
• compromised privacy and safety;
• infringement of setbacks; and,
• likely damage to a number of exceptional trees on the site and in Bill Pye Park.

The new development now proposing nine units makes some gesture toward a couple of the issues by reducing the density by one 50 sqm unit and pushing the setback to Bill Pye Park by an extra metre and by reducing the carpark by one space. This small change allowed the personal private space of the tenants to be increased. The important issues not addressed included:
• solar access requirements or the amount of sun light that reaches into a unit
• safety and adequacy of parking
• impact on the registered trees and Bill Pye Park
• desired character of the design and its impact on the street scape, residents, tenants and users of Bill Pye Park.

The even bigger issues not resolved by either ACAT or the new proposal was the consideration realistic alternatives to the proposed development. Also consideration of one of the key objectives of community facilities zoned land in the Territory Plan which is to protect community facilities land from competing uses which clearly are commercial or residential uses.

This development has been assisted by amendments to the Territory Plan. Firstly in the early 2000s, by allowing Supported Accommodation as a permissible use. And most recently, after the Tribunal decision, a technical amendment that enabled the need for parking to be separated from the dwelling type and also that the shade from vegetation not to considered in determining solar access. It is hard to understand the basis for these technical amendments other than to support the proposed development and block consideration of issues raised by residents and future tenants.
The proponents appear to have significant influence on the actions of the Planning Authority as well as significant opportunity to have opinion pieces published in the media. Residents who are impacted most by planning decisions seem to have no access or influence.

I remember a current ministerial member of the Greens giving advice at the start of engagement by residents with this planning process. The process is heavily weighted toward the proponent and the consultation has been poor but we’ll fix this when we’re in Government. Still waiting. There has been no support for constituents from local members.

When the proponent found out that the approval for their proposal had been reversed they were not happy and took to the media to cancel old white men, NIMBYs, minority of residents and even sporting humour. Despite the independent work of the Tribunal members, I didn’t realise that against us would be the proponents, the planning authority, a small army of paid old male industry experts representing the proponent and the Government. The reaction of a mature white woman to the Tribunal’s decision was to die for.

Men are still making the final calls on women's safety

Frances Crimmins is chief executive officer of YWCA Canberra. September 8 2021
Published in the Canberra Times as an opinion piece (excerpt).

The eye-watering increase in property prices and market rent in the aftermath of a very difficult year in 2020, and an unsettled economy still coming to terms with the impacts of COVID-19, mean there is a vacuum in housing options for vulnerable women across the country. Both older women and those trying to leave or rebuild lives after leaving a violent relationship are the most vulnerable in this national housing crisis.

Solutions are being sought. While I acknowledge $60 million in funding has been provided by the Commonwealth government through the Safe Places Emergency Accommodation program, it is simply not enough. YWCA Canberra is nevertheless excited to be a recipient of some of this funding, with a grant of $1.2 million to contribute to building homes for women with children and older women who have experienced violence. The ACT was awarded a total of $2 million from the program for two projects. Our housing project will be built on a block of land purchased by YWCA Canberra 30 years ago, and we still need to fund the other $1.2 million to complete the project. The project will deliver 10 units.

This is an important contribution to a problem that affects everyone in our community, and one that needs not just a government response, but a whole-of-community commitment to finding solutions. Although many may not wish to acknowledge it, domestic violence does not affect one cohort of society. There are women and children living with violence in every suburb of Canberra, from a wide range of socio-economic backgrounds and education levels.

Sadly, despite receiving approval from the ACT Planning and Land Authority, our supported housing development has hit a roadblock, with a group of locals opposing the project on the premise it is not suitable for the site.

In responding to this opposition, I have been exposed for the first time to the ACT Civil and Administrative Tribunal system. The experience has left me reeling at the realisation that our project - driven by women for women's safety - is now in the hands of predominantly older white men. That includes the parties representing opposition to the development, the senior members of the tribunal, and the ACT government's counsel. YWCA Canberra is also reliant on an all-male team of experts, and I thank each and all of them for their contributions.

However, during the five days of tribunal hearings, I was required to be silent - apart from 45 minutes being cross-examined on what support we provide and how much road traffic the development would generate. I was not even permitted to read a letter from a recently housed woman on her experience finally securing safe housing through YWCA Canberra, to demonstrate the potential impact of our development. I was silenced, and the women who I hope will eventually live in our YHomes units were silenced.

Throughout the process the men made sports analogies, batting away curveballs and continuing each others' innings, none the wiser of the experience of what it is like to make a decision to stay living in a violent relationship or to leave in the hope a service like YHomes will be waiting to give you back your dignity, hope, and a safe place to call home.

While we debate and explore the status of women's safety in Australia, it is vital we turn that gaze inwards, and examine the systems that control the delivery of key resources, like housing, to women experiencing violence.

We support more social housing for a range of disadvantaged groups across Canberra. A realistic alternative to demolishing the existing childcare and community centre and replacing it with a multi-development would be to take all the public money granted and build on land zoned appropriately for residential development. A better solution might be distributing the units amongst the developments that are to replace the thousand or so public housing units that were demolished on Northbourne Avenue. Most of this once public land remains vacant.

Resident and Community Groups have been trying to save public land across Canberra from residential redevelopment. This is happening on community facilities land and also land that is designed for sports and recreation and green open space. Government studies show that there is an increasing need for these facilities yet the Planning and Development Authority is not planning to protect these sites to ensure they are available now and for the future. They might need to shorten their name to the Development Authority.

We know these sites are important for a healthy and well connected community and getting rarer. Hardly a month goes by without another announcement that a multi-unit development will be built on concessional community land by a developer, community organisation, cash-strapped sporting club or church group. That’s why the Ainslie Residents Association (ARA) is calling for a moratorium on residential redevelopment on community land.

I am a town planner and heritage researcher based in Dickson. I am primarily concerned that the selection of this site ignores the historic aboriginal and early European significance of what is now Bill Pye Park in Ainslie, and that the proposal is inconsistent with the Territory Plan and the Planning and Development Act. I would further contend that the design fits poorly in this setting and its streetscape, despite being an improvement on the earlier plans that ACAT refused.

I have been researching the Territory's early aboriginal tracks and stock routes for some time now. An important track linking Ngunnawal Country to Wiradjuri and Gundungurra Country further north ran through what are now the suburbs of Ainslie, Dickson, and Watson. By 1838, that track was drawn on the Larmer survey of Robert Campbell's Portions 25 and 26, and continued to be shown on later maps and surveys in 1880, 1909, 1913 etc. and cited as a public road, R.1943 1603. The track passed directly through Bill Pye Park, and by the mid 1920s was being used as a stock route. It continued to be used as a stock route during World War II based on later military surveys.

Corroboree Park, where James Ainslie is recorded having established his first camp, was intersected by two creek lines and this early track.

Military surveys show creek lines flowing in a southwest direction, through what are now a series of small parks in Ainslie, including Bill Pye Park. This would explain why the route was used for such an extended period, as vegetated areas and likely water would have been an important resource for First Nations people and early Europeans.

Incorporating these landscapes into the plan of the national capital provides a valuable connection with the past. As our awareness and understanding of these sites, their connections and their former use grows, the long term cultural heritage opportunities they offer are real. Alienating public open space for a residential footprint that displays no recognition of its context, and presents an institutional appearance, not only diminishes the value of Bill Pye Park and its immediate surroundings. It also diminishes the heritage value of the string of parks in Ainslie for this and future generations.

I am wholeheartedly supportive of this initiative and know that housing is an essential part of re-establishing post crisis life for women who have experienced domestic violence. We know too that older women are the fastest growing cohort that will face homelessness, so we must adapt as a community to respond to this need.

I'm assuming the inspiration for this project is drawn from the amazing Women's Property Initiatives found in Victoria which have always been surprisingly absent from Canberra's housing options.

This project offers an ideal intergenerational community on site and being nestled in the heart of Ainslie connects the residents with an extremely inclusive, welcoming and supportive community.

I would love to see explanations behind the design choices, I hope that the decisions are grounded in sustainability. This might address current local residents concerns about the aesthetic of the plans. I would add that I'd like to see solar panels incorporated into the design and for the roof to be light coloured to maximise reflection.

I understand that trees will need to be removed and assume, as is standard, these will be replanted. It would be fantastic for Bill Pye Park to be the home to a Micro Forest with the new residents contributing to the care and upkeep alongside other Ainslie residents. It affords an great opportunity for intergenerational nurturing, caring and support.

This site has been shockingly underutilised for years and its former purpose as a childcare and community centre is no longer the pressing need for Ainslie.

Conjecture about future residents needs and wants should not carry greater weight than their voices. I assume the YWCA has consulted its future residents on the plans.

I understand concerns about property size; ultimately it's natural for people to transition to smaller accommodation later in life and smaller properties are often better suited to need. The idea of increasing the size and sacrificing being able to help more people would be hugely disappointing particular given the benefits of a smaller environmental footprint. It also gives more women the opportunity to live in Ainslie which is a beautiful, caring and welcoming.

Living through lockdowns over the last 2 years it is apparent that isolation and loneliness is a huge issue. Community is essential for navigating uncertain futures. A community housing model like this fosters community within the wider community. Our focus needs to turn from individualism to community connection and response.

I'm delighted to see that overwhelmingly Ainslie residents are supportive of this development with design concerns hardly a barrier to it proceeding. Given the urgency of safe and secure housing to re-establishing lives, further delays really need to be avoided.

FIT FOR PURPOSE?
We all agree that there needs to be more affordable accommodation for disadvantaged people whether they have mental health issues, exiting prison, a disability, or low income. To be respectful to these people the form of the housing has to be appropriate to their needs. Recently I’ve asked older women if they had the choice would they rather live in a detached house or with eight others in studio or one bedroom units. There was no surprise in their answer. They would like to live in a house that was similar to other people so that the housing would not label them as disadvantaged. They would like a house that was safe and could provide privacy. They wanted a place that they could call home and pack it full of their stuff. It would have room for friends and family. From the outside it would provide anonymity. The home would provide a platform to participate in community life. There would be none of the potential stigma that comes from the ‘Oh you live in Women’s Place House? Are you OK?’

The notion of building a facility with nine units all for women who have experienced domestic violence seems incongruous. Similarly it would be strange to group together in a relatively small space groups of men or teenagers who had suffered mental or physical abuse. This is institutional thinking and the proposed building design reflects this. It looks like a health facility and stands out in the location. There is certainly no anonymity or privacy. Being surrounded by unlit public open space and other aspects of the design has raised questions about safety.

In the nine units, two are for families escaping domestic violence. Kids and teenagers need their own space and come with a lot of stuff. Where do they play with friends? There’s not much room on the site as it’s mostly taken up with buildings and carpark. Depending how old they are the kids could free-range into the park and beyond. The development proposal comes with little detail on how the facility will operate but presumably it will be a short term option for most of the tenants.

Given the source of funding the facility is likely to provide short-term emergency accommodation. It is known that most of the funding is provided by Government. The Commonwealth Government is providing most of the construction funding ($1.2 million) through the Safe Places Emergency Accommodation Program where the grant recipient is required to report annually for 15 years that the accommodation is being used for emergency or crisis accommodation and name the organisations that supplied the specialist services. This aligns with the definition of a ‘special dwelling’ in the Territory Plan ‘to provide shelter and support for persons with persons with special accommodation needs’. The YWCA will not provide the details of this contractual arrangement stating that its commercial-in-confidence. A number of residents have questioned whether the design of this facility is ‘fit-for-purpose’ particularly due to the safety issues. Ongoing operational funding including specialist services will be covered by a combination of tenants rent and ACT Government grants. The land has been provided by the community and requires the demolition of an existing childcare and community centre building which the YWCA acquired through a concessional below-market transaction (~$170,000).

Given that this proposal is largely publicly resourced and funded for women escaping domestic violence the design could be much more sensitive to their needs. The Government should spend our resources and money on a form of accommodation that provides space, security and anonymity for these women. Provide them with a home of their choice that enables them to participate in community on their terms because this is important for all of us.

Please could you provide me with DA plans for 15 Sewell Place, Macgregor. A member of my family bought 13 Sewell Place after the DA had been approved. This means we were not given the opportunity to view the plans that had been approved. While it is obviously too late to provide comment we feel we have the right to at least see what has been approved to be built next door.

Thank you,
Caroline Wenger

I am fully in support of the proposal for all the reasons stated above about older women having done a lot of heavy-lifting and having to bear the brunt of lower superannuation etc. We all know that we/they are at higher risk of homelessness.
It sounds like a little bit of tweaking in terms of design needs to be done as mentioned by some other people and the community and childcare centre could be moved to the Ainslie shops in the disused building.

The problem with this development is not the purpose of the development, which is clearly needed, but the design. Ainslie deserves better than this, the women that it is being built for deserve better than this! This needs to be rethought and redesigned. In this day and age surely we can do better for our communities and our environment as a whole. I object strongly to this development in its current form.

Housing for disadvantaged older women is critical - they are falling through the gaps in this city
However - there are cooperative designs that embrace the possibility of co-gardening communal spaces
Design conscious of disability and access and communication as well as privacy
But please help these women not only to have a roof but a place they can thrive and connect

Building Design and Integration with the desired character of the suburb

Social housing is really important because the market does not produce housing for those who are disadvantaged. Most profit is earned targeting the top income earners and that’s who housing developers are chasing.

We support the planned development of more social housing and think the Government’ target of 15% should be implemented. But we don’t think that social housing should require the demolition of community facilities designed as a childcare centre and community centre. Social housing should be blended into existing residential housing in a salt and pepper approach so that tenants are less likely to be stigmatised.

A big problem with the proposed development at Rutherford Crescent is its density and design. There are numerous private and public duel occupancy developments in the area including Rutherford Crescent. The residential planning laws allow for 2 separate dwellings on the standard residential block. A good social outcome for the tenants is that it’s hard to distinguish between private and public housing residents. Unfortunately the design of the proposed development reminds you of institutional buildings like health centres or childcare centres. Especially with the big carport facing the street. The sharp edges, bulk of the building stands out like dog’s ####s. The previous proposal was for ten units. This second proposal is for nine units and little else has changed. In assessing whether the previous proposal met the Territory Plan’s ‘desired character’ test for Ainslie the members of the ACT Administrative Tribunal stated that,
‘… the development proposal provides for change of a different order in terms of its immediate and potential long term negative effects on the landscape character of the park, flora and fauna habitats, streetscape and amenity for residents and other park users. The contrast with what is there now could not be more striking. [Allen & ors v ACTPLA ACAT 88 para 161]

The existing community facility sits neatly under a cool canopy of trees fitting comfortably within Bill Pye Park and is ripe for adaptable reuse. Instead 15 of the 18 trees will be removed and the majority of the site covered by dark roof, hard surfaces and carpark. The last thing this area needs is a heat sink.

We are hoping that the ACTPLA assessment team puts more effort into listening to issues raised by the residents and complying with the requirements of the Territory Plan rather than providing only the developer with exceptional customer service.

Older women seem to be a cohort forgotten by the wider community and left vulnerable. I echo Gina Dow's comments - women do a lot of heavy lifting in the community, often suffering poor incomes and appallingly low levels of superannuation as a result. There should be developments like this peppered across the country, and they should be in keeping with the surrounding streets.

I'm fully in support of this proposal. Older women are the cohort most at risk of homelessness. I believe the design needs a rethink. It is not in keeping with the surrounding suburb.

I'd really like to support a development like that for all the reasons Gina puts forward, but gosh that design is just SO ugly, quite unnecessarily so. Surely - really, surely - we can do better than that. Some of the designs used around Ainslie for single level units are pretty good. If the design better followed the character of Ainslie, as Ian has suggested, perhaps there would be less opposition to the development. It feels like the designers are on the offensive with a proposal like this and for that reason if I lived near that Park I would also really object. Its not hard to do better and be a bit more sensitive to how people feel in Ainslie.

I am in favour of this development and would like to see housing for 100 more disadvantaged women developed in and adjoining Ainslie’s open spaces. Older women are at particular risk of homelessness - thanks to structural inequality throughout life. Bill Pye Park is a large space and the loss of some trees is being weighed up against a vitally necessary housing resource. Let’s give older women a break, start redressing superannuation and wage gap problems coming home to roost, and welcome the tenants into amenities-rich and beautiful Ainslie. The unused building behind the Ainslie shops can be repurposed for childcare. Note also that older women tend to be lifters and volunteers - and will be sure to propagate and otherwise support the proposed micro forest for Bill Pye Park.

This development will have a significant impact on Bill Pye Park, including the health of a number of mature trees. The design of the building itself contrasts strongly with the streetscape and desired character of the area. Constructing 9 units on this site, 1820 square meters, is almost twice the density of development allowed on adjacent and neighbouring blocks. This will impact the amenity, safety and streetscape for local residents. The congestion on the site and the overshadowing by trees will result in lifestyle and safety impacts for the proposed future tenants.

This proposal will result in the demolition of community facility building with a lease purpose requiring a childcare centre and community centre. These facilities are required in Ainslie. The community will no longer have access to the site.

There are a number of other issues with this proposed development which I will expand open later.

Thank you for the opportunity to lodge an objection.

Can I suggest that since you are going to move and reconstruct the verge and the bus stop, that you consider doing a cut in to allow buses to pull in out of the way of the traffic using Vasey Crescent. This street is not wide enough to allow for two way traffic when the bus has stopped or there are cars parked. The road has a curve in it which obscures the view of traffic coming in the other direction which makes it quite hazardous.

Can you, as part of this work, construct a suitable entrance for riders to the Stromlo Forest Park on the opposite corner of Eucembene Drive and Cotter road. At present there is only a small gap in the fence accessed through the gravel area on the side of the road. A short sealed bike path, from the gate linking to the southern car park, would be ideal.

I am confused as to whether this work is to be done on Chauvel St or Vasey. Or maybe both? The heading says 25 Chauvel but the text says Vasey. Can you please clarify?

Any/all upgrades are gratefully appreciated.

Cheers

I own the property which abuts 19 Cordeaux Street Duffy to its boundary with Tantangara Street. I have four issues regarding this application:

1. My front door faces west directly into the property in question. There is no evidence from the paperwork provided as to what my outlook from this perspective will be. I understand it will be facing Unit 3 as per plans, but documents do not give my eyesight view. Please provide this.
2. According to the plans, Unit 3 will have windows that will overlook my property. There is no evidence as to whether these windows will have privacy screens or frosted glass. Please provide this.
3. The one 'tree' (actually more of a shrub) identified on the plans is not a native to Australia. This means that it will not attract birds and will not fit in with the majority of the treescape in Duffy. A native tree would therefore be more preferable. This affects me personally as it appears a 'tree' is to be planted near my boundary with Unit 3.
4. This development is likely to take some months - perhaps even as long as a year - what action will be taken to ensure that there is minimal disruption to neighbours in terms of noise, dust, and construction activities? Please provide this.

This proposed development is interesting from an architectural and social housing perspective by enabling cohousing where a number of groups can live on the same site independently and also share some facilities. It is questionable whether this is very different from many of the larger houses in the area that are used as shared accommodation. There are houses close by that are used as shared student housing, houses where two families share, multiple generations or a number of singles or couples share.

The differentiating factor is the need for a planning variation includes the allowance for three dwellings rather than the RZ1 allowance of two dwellings and the reduction in car spaces from one per dwelling reduced to two. Based on the notion that the cars will be shared. Again there are plenty of nearby single dwelling examples where cars are shared.

The planning guidelines need to have a longer view that extends beyond a proposal based on current tenants. When these current residents move on how is their unit passed on, transferred or sold? How would the parking work if there were three couples and six cars? Is there a risk that in the future they become three seperate units and the shared facilities becomes a fourth unit.

It is possible that the development would have greater future flexibility if it were built in a residential zone that enabled seperate titling of the three dwellings. The planning requirements of RZ1 would not need to be compromised. The demonstration projects are all interesting from an architectural and social housing perspective but some also compromise existing and important planning controls where they need not. Developers may see an advantage if density controls are reduced.

Comment on Development Application: 202139359 for 5 McLean Place, Curtin

I regualarly walk the Radburn paths and briefly I would like to make the following points:
- the proposal as it is drawn up seems to contradict the Radburn residential design followed by every other home in the vacinity
- the building set back does not appear to comply with standard requirements for the block when compared to the existing structures
- the fence (again which does not seem to comply with requirements) will have a visual and physical impact on the park out of keeping with the neighbouring houses and the Radburn design principles; the principles that underscore the reason why people have chosen to live in that community.
- it would appear that the block was purchased without thought to the existing Radburn residential design. It would be detrimental to allow one poorly planned development ruin the existing community when a more sympathetically designed development is achievable.

Thank you.

Comment on Development Application: 202139359 for 5 McLean Place, Curtin

5 McLean Place is in the Radburn residential area of Curtin. Key Radburn design principles evident in this area of Curtin include: houses face the parkland; the parkland merges with the front yards of private properties; houses and fences are kept well back from the park front property line; and with foot and cycle traffic directed through the park and garages located on the service road side of blocks, motor traffic is kept, as far as possible, separate from foot and cycle traffic. These features are not respected in this DA.
• Neither of the houses face the park and one of them has no boundary with the park. For the house which does, the design shows no gate on the park side so even residents in that house cannot directly access the park. Foot and cycle traffic is therefore via the service road which means a mingling of foot/cycle traffic with motor vehicles.
• The park side fence on the property line is high, continuous (without a gate) and solid. Lost therefore would be any sense of continuity between private and the public space. Compared with most other parts of Radburn, the parkland between Blyth and McLean is very narrow (3-4 metres). Consequently with the fence located as proposed, the park at this point would become little more than a path.
• The building set back is less than 3 metres from the park side property line, even though the general planning rules require a 4 metre set back (to open space wider than 6 metres) or 6 metres in most other cases. Taking into account the very narrow park mentioned above, even in the absence of a fence the small set back proposed would significantly compromise the parkland qualities of this area of Radburn.

There is a place for dual occupancies in this area of Curtin given its proximity to shopping, schools and other facilities and the attractions of Radburn itself, in particular its parkland, trees and footpaths. But this proposal does not take best advantage of the attractions offered by Radburn and in fact damages the very features which make this area of Curtin attractive.

For this proposal to be approved, both houses should have access to the park, the set back on the park side should be 6 metres and the park side fence should be at or behind the building line.

Reynolds Street is being over developed. The redevelopment is inconsistent with the character of the suburb. There are traffic implications. There is a loss of tree cover, and an extension of hard surfaces which add to the heat island effect and the amount of water runoff. There needs to be step back from such developments in Reynolds and surrounding streets with some overall planning rather than these ad hoc developments.