Exhibition Period: Friday, 21 November 2025 – Midnight Friday, 19 December 2025
Address: Lot 05182 Town of Darwin
213 DICK WARD DR LUDMILLA
Current Zones: MZ (Multi Zone)
Proposed Development:
Mixed use development comprising shops, restaurants and a service station in 3 x 1 storey buildings and an amended masterplan for specific use zone SD37
Template for a possible submission:
Flyer to download and print out:
PLan submissions:
It is PLan’s opinion that the applications are so poorly prepared including the omission of key documents in the initial upload that the whole package should be returned to the developer.
PLan also notes that there has been no community consultation on what will be a major change to the amenity and environment of the location.
Further PLan questions the logic of massive construction projects in flood zones in a cyclone prone location. It may be prudent to check that the City of Darwin are ready to accept liability going forward.
Submission One
Development Application PA2025/0441
Part Lot 5182, Bagot Road / Dick Ward Drive / Fitzer Drive, Ludmilla
Grounds for objection
This submission objects to Development Application PA2025/0441 on the basis that the proposal is not capable of being fully or reliably assessed because it depends on two unapproved applications, unbuilt infrastructure and unresolved technical matters..
The application seeks approval for development in advance of the planning framework, land configuration and access infrastructure it relies upon.
The application is not stand-alone and cannot be assessed in isolation
The Stage 1 Masterplan states that this Development Application is one of three concurrent applications:
• variation to Development Permit DP14/0831 (subdivision)
• variation to the SD37 Masterplan
• Stage 1 Development Application
This Development Application depends on the approval of the other two applications. Because the controlling Masterplan is still under variation, and because the proposal relies on a subdivision layout that is not yet approved, the application cannot be treated as a fully stand-alone development at this stage. The planning framework that Stage 1 depends on is not yet settled, and the amended Masterplan being applied for is not a minor variation to the endorsed 2014 Masterplan because it introduces a new built-form staging structure that does not exist in the current approved Masterplan
The application acknowledges that the only endorsed Masterplan is the 2014 Masterplan, and that a new Masterplan is being applied for as part of this DA process.
Approval of Stage 1 would therefore occur before the amended Masterplan is endorsed.
This raises procedural concerns. Development is ordinarily assessed against an approved Masterplan, rather than proceeding at the same time a new Masterplan is being sought.
Stage 1 relies on a subdivision layout that is not yet approved
The Stage 1 development area corresponds to a future lot that depends on approval of a variation to DP14/0831. Because that subdivision variation has not yet been approved, the land configuration shown in the Stage 1 documents does not currently exist in its proposed form. This means the assessment of Stage 1 is taking place before the relevant subdivision pattern is settled.
Traffic and access remain unresolved in the exhibited material
The Stage 1 Masterplan indicates that vehicle access to the site requires the construction of a new road connection between Bagot Road and Dick Ward Drive. That road has not yet been built, and the internal roads shown in the plans are private roads that would also require further approvals. Because these access arrangements are not yet in place, the proposal relies on road infrastructure that appears still uncertain
Key works are deferred to future applications
The application indicates that several essential components of the development will be addressed through later approvals. It notes that further applications will be required for roads and drainage and that a separate earthworks application will be lodged. It also notes that utility connections depend on approvals from external authorities.
As a result, this Development Application does not set out how drainage, earthworks, road construction, site remediation or coordination of services will be delivered. Approval for Stage 1 is being sought before these matters are fully defined.
Planning Act compliance is asserted rather than demonstrated
The application refers to the Planning Act 1999 as the basis for lodging the proposal. At the same time, the material acknowledges that key components of the planning framework are still in progress. The amended Masterplan has not yet been approved, the subdivision layout is still under variation, the access road has not been constructed, and a separate earthworks application is expected to be lodged later. Several dependencies are therefore still unresolved.
In these circumstances, it is difficult to see how compliance with the Planning Act can be demonstrated when the underlying planning framework is not yet settled.
Conclusion
This Development Application depends on two other applications that have not yet been approved, relies on road infrastructure that is not yet built, and proposes development on a lot that is still subject to a subdivision variation. Key engineering, drainage and earthworks matters are deferred to future applications, and the proposal is being assessed before the amended Masterplan that it relies on is finalised. For these reasons, it is difficult to assess Stage 1 in isolation from the broader planning framework and the information that will be supplied in later applications.
Request
For the above reasons, Development Application PA2025/0441 should be refused
Reference list
2014 Endorsed Masterplan prepared by Planit Consulting
2014 endorsed master plan by planit consulting.pdf
2014 Development Application Report prepared by Planit Consulting
2014 Development Application report prepared by Planit Consulting.pdf
SUBMISSION TWO
PA2025/0441 — Part Lot 5182, Bagot Road / Dick Ward Drive / Fitzer Drive, Ludmilla
Objection to endorsement of the November 2025 Amended Masterplan under SD37
This application seeks endorsement of a new Masterplan by the Consent Authority. Under SD37, a Masterplan only has effect once endorsed. If this document is endorsed, it replaces the currently approved 2014 Masterplan. This means the application is not only for development approval but also for the approval of a new planning instrument for the site.
This submission is based on the applicant’s Masterplan and supporting material, including the Amended Masterplan under SD37 (Sargeant Planning, November 2025), the Statement of Effect – Amended Masterplan under SD37 (November 2025), the Traffic Impact Assessment by Rytenskild Traffic Engineering (13 November 2025), the endorsed 2014 Masterplan prepared by Planit Consulting, and the Planning Act 1999 (NT) and NT Planning Scheme (SD37).
This is not a minor variation to the 2014 Masterplan
The 2014 Planit Masterplan is the endorsed planning framework. The November 2025 Masterplan changes the internal road layout, adjusts access points, modifies building locations, reorganises parking, changes the use of Area A, and introduces retail as a primary land use. These changes represent a shift from the current endorsed framework. If endorsed, the November 2025 Masterplan replaces the 2014 Masterplan.
Retail becomes the primary land use
The Vision and land‑use sections of the November 2025 Masterplan identify supermarket retail, large‑format retail, takeaway food outlets, a service station and other commercial uses as the main functions of Area A. In the 2014 Masterplan, retail was secondary. Under the amended Masterplan, retail becomes the dominant land use within the development footprint.
The drawings indicate a new planning framework
The amended drawings include a different internal road network, new entry and exit points, relocated buildings, a revised lot layout, a parking structure and expanded sealed areas. These changes do not fit within the 2014 Masterplan framework.
Endorsement resets the planning baseline
If the amended Masterplan is endorsed, the 2014 framework is replaced. The new layout becomes the reference framework for future development approvals, including land‑use intensity, road layout and development form.
The Statement of Effect relies on the new Masterplan
The Statement of Effect explains the proposal by reference to the amended layout and new structure. It does not assess the proposal against the 2014 Masterplan. Endorsement of the new Masterplan therefore becomes a necessary step before the development can proceed.
Legal and scheme grounds
Planning frameworks should be settled before development is approved
Under SD37, development is intended to proceed in accordance with an endorsed Masterplan. In this case, the applicant seeks development approval while the planning framework itself is still being considered. This reverses the expected planning sequence.
A Masterplan is a controlling planning instrument
Under the NT Planning Scheme, a Masterplan determines land‑use focus, access arrangements, development footprint, layout and staging. Endorsing a new Masterplan sets the planning framework for all subsequent development. It is a substantial planning decision, not a minor administrative adjustment.
Public participation is affected if change is minimised
Public participation depends on clarity about what is being decided. Describing the 2025 Masterplan as a variation may understate the scale of change and may limit public understanding of the implications of endorsement.
Risk should not be moved into the future
A Masterplan is expected to address key risks before development proceeds. Endorsing a new framework while deferring infrastructure details, traffic resolution and the effects of land‑use change shifts risk away from the decision point.
Public interest
The Planning Act requires decisions to serve the public interest, including transparency, accountability and responsible sequencing of land‑use decisions. Approving a new Masterplan while key constraints and impacts remain unresolved may shift planning risk from the proponent to the community.
Request
We request that the Consent Authority not endorse the November 2025 Masterplan as a minor variation of the 2014 Masterplan within the current Development Application. Instead, we ask that the 2025 Masterplan be publicly exhibited and assessed as a new planning instrument before any development relying on it is considered.
References
Amended Masterplan under SD37, Sargeant Planning, November 2025
Statement of Effect – Amended Masterplan under SD37, November 2025
Traffic Impact Assessment, Rytenskild Traffic Engineering, 13 November 2025
Endorsed Masterplan, Planit Consulting Pty Ltd, 19 September 2014
Planning Act 1999 (NT) and NT Planning Scheme (SD37)
Submitter
Nicholas kirlew
Convenor of PLan – the Planning Action Network Inc
nick@planinc.org.au