At time of writing we are getting close to the hearing for PA2025/0441
Bagot Road Masterplan variation and DA Stage 1
Below are documents that have been made available.
Some random comments:
I would point out that the quality of the application and subsequent comments are of a less than convincing manner.
The use of a master plan that was developed under previous acts and schemes continues what Plan considers to “fail the pub test”, much has changed since the original master plan and a clean start would be an obvious choice.
It could also be considered an unfair playing field given the communities lack of resources.
If a definition of this sentence be provided perhaps? There are many other examples.
” A Master Plan has been previously approved the varied Master Plan as detailed above delivers the required landscape buffer and increases the size of this landscaped buffer open space. It can be deduced that amenity would be further preserved through this variation.”
I would ask who actually believes we need another commercial zone with petrol station? At what point does the justification show that particular attribute of the proposal is a good thing?
From the applicant: “Whilst land surface temperatures may be a relevant contextual feature of the locality there is no specific control relative to the matter nor measurable outcome or object within the scheme required to be met.” This would infer that we will get what ever they want to do. At this stage of the City of Darwin’s maturity do we have no protections from the construction of these heat sinks?
This sentence “Through this landscaping on site may be more robust.” Is that a statement we can take to the bank, or rather to the city of the future? The lease holder cannot point to any commercial facility that they have endowed on the city and show successful heat mitigation.
The lack of clarity over what is happening in the flood zone is frightening, a commitment to doing something in the future is not convincing in any manner. I am not sure that I would be able to prepare a document in my workplace that throughout refers to Attachment xxx. Why are they allowed to be this lax in this most critical of stages?
The City of Darwin points out they don’t have enough information to assess. The applicant says that have done multiple briefings, who are we to believe?
The proponent states “Our client also provided media briefings to media outlets for wider community awareness on the proposed development and application. This was utilised in local newspapers and other media.”
That is a stretch of imagination, when approached the local member Lauri Zeo advises she had no information about the proposal. Plan are fully justified in calling out any claim to community consultation. There is no outreach documented or noticed.
The argument the landowner thinks the project is a good idea does not address what the impact of the project on the subject land and surrounds.
Again “Our client has also sought to broadly engage with the community through media releases over the intent to develop and drawn attention to the proposal through the local paper and other media.”
We can provide any number of residents who will attest to the fallacy of this statement.
Where is this based? “Creation of new employment generating land uses both during construction and more importantly, on an ongoing basis once the development is complete and operational. This includes youth employment opportunities with retail developments employing a large number of younger staff.” Is there a basis for this?
ADG kick a goal here: “ADG also notes from the 9 December 2025 briefing session that the proponent is likely to further subdivide these lots in the future. This reinforces the importance of appropriately documenting the above development considerations within the lot and staging plans, so they are addressed comprehensively and not in a fragmented, piecemeal fashion.”
Plan concurs. “These objections to development of the site, given the absence of NT Planning controls over the airport land, may be considered by some to be commercially motivated”, is that the pot calling the kettle black?
This is the applicant describing their own documents: “In respect to the solar farm aspect this is not a use sought for approval its notation on the master plan may be considered presumptuous and misleading.”
There is then a section on noise, Plan would ask who came first? People move and then complain, perhaps maintaining buffer zones was a good idea? Earlier we had improved pedestrian traffic and landscape use and now we have “Outdoor exposure is limited, to pathways and carparking resulting in infrequent use and over limited periods.” Did anyone tell the shoppers and business owners that?
Back onto water: “Importantly development of the site will not result in real property damage up or downstream and will be demonstrated with each stage of development at the relevant time.” Is that “trust me?”
At this point there is duplication of objections and answers, again pointing to a lack of concern for the audience of the document. If the applicant cannot create a concise document what hope do we have on the development itself? Heavy reliance on cut and paste is not a good plan for mutual understanding.
To other responses, this stands out:
“No supermarket based centre exists between the City and Nightcliff. This development will service this void in the catchment and is also convenient for tourists/travellers.” There are plenty of locations in the NT without supermarkets. Where is the justifiable statistics?. J
This statement indicates a whole new way of constructing buildings has been discovered by the applicant: “The proposal does not seek to excavate the site and mobilise contaminant material and or groundwater contaminants.”
I would like to hear from any home owner in Ludmilla agree to this: “We also note the downstream owners consent to the application and the property interface with the ocean/Darwin Harbour. The tidal influence on the allotment is substantive.”
Plan notes that has yet to carried out effectively in any development for many years: “The site does salvage protected plants cycad and other non protected native species for reuse”
SUBMISSION to Proponent’s Characterisation of LOT 5182 Application PA2025/0441
This submission responds specifically to the proponent’s comments to community submissions framing of Part Lot 5182 as degraded land only good for development.
Definition and Context
Part Lot 5182, known locally as the Ludmilla bush block, is a substantial woodland area in the Darwin mid-suburbs. It is directly opposite homes in Fitzer Drive and is highly visible from Bagot Road and Dick Ward Drive. Residents refer to it as the bush block because it retains the character, structure and behaviour of remnant woodland within an urban setting.
Characterisation of the Land as “Degraded”
In responding to community submissions, the proponent repeatedly describes the Ludmilla bush block as degraded, contaminated, illegally dumped upon and burnt. That description is then used to frame commercial development as an improvement.
Degradation is a condition of management. It is not a measure of ecological, cultural or planning value.
Land that has been neglected does not cease to perform environmental, hydrological, canopy or spatial functions. A site may appear degraded and still contribute to flood storage, biodiversity, urban cooling and landscape buffering within the broader urban structure.
Planning assessment should focus on the functions the land currently performs, including flood storage, stormwater moderation, canopy cover, biodiversity habitat and spatial buffering, and whether the proposed development would improve or diminish those functions.
Contamination and Flooding
The proponent acknowledges historic dumping and fill, and describes the land as contaminated and flood affected with wet season waterlogging and slow drainage. However the proponent does not explain clearly how earthwork disturbance, extensive clearing, fill placement and drainage changes will avoid mobilising contaminated material or altering wet season flow paths beyond the site. Instead, the proponent repeatedly asserts that impacts can be managed through a future yet to be finalised RAP and a proposed contamination cell, without providing the specific details needed to test that claim, particularly as these matters are still unresolved while the DCA is in the process of assessing site suitability.
The proponent’s response asserts improvement through built form, retail activation and landscaping, but does not demonstrate how the amended Masterplan improves environmental performance relative to the site’s existing hydrological and ecological role.
Amenity Framing and Ludmilla
The proponent refers to aircraft noise, traffic and what is described as degraded land opposite Ludmilla residents when addressing amenity concerns. The response suggests that additional impacts from a proposed development that includes approximately 510 car parking spaces, a large retail centre and a 24-hour service station should be given less weight, and claims that the proposed development will improve residential amenity.
The existence of aircraft noise or traffic does not remove the obligation to assess whether the proposed commercial intensity protects or diminishes residential amenity. Residents value both their suburb and the adjoining bush block. Amenity must be assessed in terms of noise, lighting, traffic, trading hours and cumulative effect.
The suggestion that amenity can only be improved through commercial redevelopment does not engage with the possibility that restoration and rehabilitation of the bush block could also improve amenity and is more aligned to the original purpose of the lease.
Purpose of the Lease and Spatial Role
The proponent’s responses do not engage with the historical conservation purpose underpinning the lease, nor with the role the bush block plays within the mid-suburbs landscape structure.
Exhibited ecological reports acknowledge mature native species remain established on the site despite disturbance and weeds including Bloodwood Darwin Woollybutt and Stringybark, along with Pandanus and cycads and that the site is still used extensively by native fauna.
Available data show that Darwin has already lost a significant amount of its urban tree canopy. The CSIRO Darwin Living Lab estimated an approximate 33 per cent decline in canopy cover between 2016 and 2021. Cyclone Marcus removed large areas of canopy across Darwin, and Cyclone Fina has again caused widespread tree loss. This level of loss directly affects shade, urban cooling, and biodiversity and make the protection of remaining woodland a priority.
The City of Darwin Municipal Plan 2024–25, the Greening Darwin Strategy and Climate Emergency Strategy all emphasise the importance of retaining and expanding tree canopy and green infrastructure as part of the city’s response to increasing heat and climate stress.
The Darwin Mid-Suburbs Area Plan also recognises the importance of retaining green space, tree canopy and environmental character across the mid suburbs as part of managing heat, amenity and long-term liveability. It identifies increasing urban density and development pressure as issues that must be balanced against the protection of existing vegetation, canopy and environmentally sensitive land. It supports development being directed in ways that do not result in the continued loss of the mid suburb’s remaining green areas and encourages the protection of vegetation where it still exists.
Part Lot 5182 directly fits within this context. The Ludmilla bush block is one of the remaining areas of established woodland in the mid-suburbs and continues to perform exactly the kind of environmental role the Area Plan seeks to retain, shade, vegetation cover and buffering from surrounding road corridors.
Development that clears and fills this land removes green space from an area already under urban pressure and moves in the opposite direction to the planning intent expressed in the Area Plan for the mid-suburbs.
The proponent’s responses focus on zoning status and development permissibility, and relies on the claim that the varied Master Plan retains over 50 percent of the land as open space and that clearing impacts are reduced by salvaging plants for reuse in landscaping. This open space land referred to is the section zoned RD which is within PSS. The proponent refers to vegetation retention and landscaping within this RD PSS zoned area which also will contain the proposed contamination containment cell. The proponent does not however clearly explain the extent to which that area will be cleared, reshaped or engineered as part of the overall earthworks. They state existing vegetation is to be retained and regenerated in the open area where not affected by earthworks and remediation works and the contamination containment works. What does that actually mean in terms of the clearing of native woodland in the RD area? The proponent continually asserts that no significant impact to biodiversity would arise from this development, and that the RD area retained as open space will help address urban heat. These assertions do not address whether the exact extent of clearing across the site and whether this aligns with broader planning objectives on retaining established urban canopy and vegetation.
Conclusion
The key issue for assessment is whether clearing and filling large sections of the Ludmilla bush block for intensive commercial development represents an environmental and planning improvement when assessed against its existing ecological, hydrological, spatial, cultural and community role.
I respectfully request that these matters be explicitly addressed in the assessment report.