Caroline Le Couteur MLA

ACT Greens Member for Murrumbidgee

Friday, 9 March 2018

Submission to EPSDD Housing Choices discussion paper

March 2018
INTRODUCTION
Residential zones cover most of the urban area of Canberra, including the majority of land in
our new suburbs. Development in these areas has a huge impact on the lives of Canberrans,
our environment and the future of our city. It influences such diverse issues as:

• The affordability and availability of housing

• The local environment through the appearance of our residential areas, tree and
canopy cover (the heat-island effect) and local traffic

• Our broader environment, through the impact of the buildings themselves – and the
city they are part of – on climate change.
As stated in the Housing Choices Discussion Paper, the rules for development in our
residential areas have not had a major review for well over a decade. The Canberra
community has changed substantially over this time and issues like population growth,
climate change and housing affordability have grown even more pressing.
I would like to thank the Government for creating the opportunity for the community to
debate the planning rules for our residential areas. There are many challenges which offer
new opportunities for positive changes in our community. I would encourage the
Government to work collaboratively with the many community groups, interested residents
and stakeholder groups to seek a path to change that will have broad support.

OBJECTIVES
The Housing Choices paper focusses on providing the ‘missing middle’. While this is an issue
that needs to be addressed, I believe that it is not possible for the ‘Housing Choices’ process
to focus on the ‘missing middle’ alone.
The impact of changes made to the planning rules for one purpose can have major impacts
in other areas. For example, restricting the development of dual occupancies in the RZ1
zone has not stopped change – rather in many suburbs it has instead diverted re-
development into extremely-large McMansions, which are unaffordable for the majority
and have a huge ‘per capita’ environmental impact, both during construction and over the
lifetime of the building. Ironically, these larger houses have reduced space for trees despite

AUSTRALIAN CAPITAL TERRITORY LEGISLATIVE ASSEMBLY

London Circuit, Canberra ACT 2601, Australia GPO Box 1020, Canberra ACT 2601, Australia
Phone +61 2 6205 1941 Email lecouteur@parliament.act.gov.au
the fact that keeping space for trees was a major concern that lead to the restriction of dual
occupancies in RZ1.
As a result, I believe that the Housing Choices review needs to be guided by a broader set of
objectives that address the long-term sustainability of our city, across social, economic and
environmental spheres. I therefore recommend that the Housing Choices process is guided
by the following set of broader objectives. (These objectives can also be regarded as my
response to the Discussion Paper’s question ‘What makes a good development?’)

Objective 1: Fill the ‘missing middle’

I largely agree with the Discussion Paper on the scope of this objective. I would emphasise
though the need to take a social sustainability approach and keep a broad focus on groups
that struggle to find suitable housing, including young people, older people and people with
a disability. There is an increasing diversity of households and needs to be an increasing
diversity of housing solutions. Options such as co-housing, hostels and boarding houses
should also be explored, with specific planning rules for the latter two to ensure they are
well designed and located appropriately.

Objective 2: Improve housing affordability

The Greens agree with the need to improve housing affordability, however, meeting this
objective needs to be more nuanced than just increasing overall housing supply. For
example:

• Cheap houses that condemn their residents to expensive commutes or high utility bills
do not lead to more affordable housing in the long term.

• ACT houses, as the discussion paper says, are getting bigger but housing less people
per dwelling. Knockdown/rebuilds are replacing smaller, older houses with large
houses. This makes housing less affordable both in upfront purchase price and
running cost. Over time, this will squeeze even median-income households out of
higher-value suburbs.

• Community and not-for-profit housing should be encouraged.

• Co-housing, hostels and boarding houses should explored, with specific planning rules
for the latter two to ensure they are well designed and located appropriately

Objective 3: Improve environmental sustainability and reduce urban sprawl

Meeting this objective would require consideration of:

• Encouraging and accelerating urban infill so as to reduce the spread of housing into
rural areas of high biodiversity.

• Prioritising housing development where the residents can walk, ride or take public
transport to services, shops and schools. This both increases the amenity for residents

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 and reduces the environmental impact from transport, which by 2020 is expected to
be the sector creating most of the ACT’s greenhouse gas emissions.

• Development that makes room for vegetation, especially trees. This will minimise the
heat island effect as well as reduce the impact of heavy rain and provide habitat for
animals and birds.

• Reducing the incentive to build very large houses, which have high embodied energy
and operating energy requirements

• Providing opportunity for residents to access ‘green spaces’ including gardens,

possibly community gardens, in their neighbourhoods. There is evidence that this is
good for people’s mental health as well as the environmental benefits.

• More incentive to build low-carbon development. The EER system is helpful but not
sufficient as it does not consider the full life cycle impact of the dwelling. Other issues
with EERs include limited-to-no consideration of obstructions to sunlight and using
climate data from last century rather than the expected future climate. There are also
improvements that could be made such as the application of mandatory solar
orientation, which should be taken into account with block consolidation
considerations.

• More incentives for renovation rather than knock-down rebuild where the basic
structure is sound and fit for purpose.

Objective 4: Increase community acceptability of infill

Meeting this objective would focus on encouraging development to respect local character
and amenity especially in the RZ1 and RZ2 zones where there is less community acceptance
of change. This means that new developments need to be designed so that: traffic impacts
do not significantly reduce amenity; useable, green open space (public and private) is
maintained; and if possible public amenities are improved.

Objective 5: Encourage high-quality design and new ideas

This objective would require considering design issues such as housing that is designed to
facilitate social interaction between neighbours (such as the Nightingale developments),
unlike current apartment blocks where neighbours never see each other. It would also
encompass higher levels of environmental sustainability. This could include Passive Haus
design, looking at the full environmental life cycle (i.e. including construction and eventual
renovation or demolition) of housing and carbon positive (e.g. net energy producing)
households. It could also encompass designing smaller-than-current average housing that
nonetheless meets the needs of the residents at a reduced financial and environmental
cost.

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Co-housing is an example of an idea that is new to Canberra (though well-established
overseas). Because the development is designed by future residents, liveability is high and
the owners seek to minimise long term costs, not just construction costs.

CURRENT DEVELOPMENT
Is the Territory Plan delivering development that meets these Objectives? Clearly, the
answer is ‘no’. This section highlights four of the shortcomings of current development
generated by the Territory Plan against the Objectives. Comments on what needs to change
are in the following section.

The ‘missing middle’

In my conversations with members of the community, there are a number of people who
are looking for terrace or small houses but are currently excluded from buying a home due
to affordability and lack of supply. Smaller blocks with small or terrace houses on them
potentially resolve these problems as the land part of the purchase price is much less than a
small, old house on a large block.
A key question is, where should the missing middle be located? In my view, it will need to
be located across Canberra, not just in certain redevelopment areas like Town Centres, to
meet the needs of different groups with different housing needs:

• Older people who downsize usually want to stay in their current neighbourhood.

• Families looking for a more affordable or more environmentally-sustainable small

home will usually want to stay near existing schools and friends

• People who need very affordable housing, for example due to low income, should be
able to find affordable options in all parts of Canberra, not be forced to the outer
fringe where their transport costs will be high.
From a Territory Plan perspective, this means tackling the RZ1 and RZ2 Zones, even though
that is very sensitive in the community.

Community acceptance

Initially, community acceptance of multi-unit infill in Canberra was low and this resulted in
the planning rules we have today. The RZ1 Zone was to be protected from redevelopment,
with lower-rise redevelopment focussed into the RZ2 Zones and taller redevelopment –
mostly apartments – directed into the RZ3, RZ4, RZ5 and Commercial Zones.
My sense from talking to many people in the community is that over the last two decades of
redevelopment, the community’s views have shifted as we have become more experienced
with what redevelopment means in practice.

• The RZ1 Zone has not been protected from change – rather, very large houses are
being built instead of dual occupancies. These houses have much the same impact on
neighbourhood character as dual occupancies used to, especially in older areas, and

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 areas with large amounts of vegetation. Large homes have also had a negative impact
on housing affordability and environmental sustainability. The Territory Plan clearly
needs to be changed to address this issue.

• Our community has changed. Many people who wanted to protect their family home
from infill now wish to move into smaller dwellings as they have aged. Ideally, they
would be able to do this in their own neighbourhood, but there are few options. The
RZ1 Zone is producing no smaller dwellings and the RZ2 Zone is producing relatively-
little infill. The RZ3 and RZ4 Zones are not available in most neighbourhoods.

• As the government notes, household sizes are decreasing, and thus there is demand
for smaller dwellings.

• Many more people have seen multi-dwelling redevelopment and have a much more
specific understanding of the issues it raises. The sticking point is now more likely to
be design quality rather than a blanket objection. Design quality can be a very broad
concern, but in my experience usually relates to the way the design impacts on the
neighbourhood, including appearance, traffic, open space, solar access, sustainability
and sheer size. The problem is the Territory Plan currently has a focus on ‘tick-and-
flick’ rules that make it difficult for design quality issues to be addressed.

The need for incentives for better quality

‘Tick-and-flick’ rules have a strong appeal. They give the community and developers
certainty. They are easy to understand and assess DAs against. However, they provide no
incentive for design quality. Most developers are responding to tick-and-flick rules with
standard designs that have no regard to:

• Good environmental design, for example carbon-neutral buildings

• Buildings that visually ‘fit in’ to the neighbourhood they are going into

• Housing that is affordable and suitable for a wide range of households

• Building communities rather than apartments, resulting in poor quality communal

open space and developments that isolate residents from their neighbours

• Ideas that are new ideas to Canberra like co-housing or tiny-houses. These have been
successful elsewhere

• Cumulative impacts of development such as traffic, stormwater generation and solar

access.
The Territory Plan’s Merit Track and Criteria system was set up to encourage developers to
produce better quality. However there is a wide-spread concern that for many
developments it is instead providing a way to achieve a lowest common denominator result,
and a route for bending the rules without much (if any) quality gain. Change is needed so
that the Territory Plan provides incentives for quality and ideas.

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No room for trees, no room for children

It is well-established that trees and other vegetation are a critical part of the ‘living
infrastructure’ of our suburbs – in fact, it is recognised in the Government’s Climate Change
Adaptation Strategy. Trees and vegetation have many benefits, including:

• Reducing the heat island effect that makes our suburbs hotter in summer

• Reducing stormwater run-off, with environmental and infrastructure cost benefits

• Local amenity benefits

• Economic benefits through higher property values.

Similarly, a growing field of research is showing that children need access to green space for
play for healthy mental development. A lack of outdoor open space also encourages a lack
of physical activity.
Sadly, our new suburbs are being built with no room at home for trees and children. This is
a direct result of the Territory Plan. In new suburbs, the planning rules for mid-sized and
compact blocks (blocks of less than 500m2) have a toxic combination of plot ratio controls
and open space controls. This is resulting in development like that shown in Figure 1 – large
houses with no room for trees and very little room for children to play.
In established suburbs, the blocks are generally larger and the rules are slightly tighter, but
the outcomes of redevelopment are only slightly better, as shown in Figure 2. Trees and
other vegetation are being lost through redevelopment and despite the large blocks, can’t
be replaced because of the small, awkward gardens.
Victoria has been experiencing similar problems and as a result has recently made changes
to its planning rules. Garden areas are now required for all development in two of its three
main residential zones.

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Figure 1: Recent suburban development in Wright (RZ1 Zone). Only 3 blocks have space for
large trees on the block and less than half have room for outdoor play

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Figure 2: Recent redevelopment in Curtin (RZ1 Zone). No room for large trees other than the
street trees out the front

RECOMMENDED CHANGES TO THE TERRITORY PLAN

The solution is bigger than the controls for the residential zones

The ‘Housing Choices’ discussion paper is focused on possible planning changes for the
residential zones. These are important, but clearly are not the only things that need to be
changed to improve Canberra’s housing. A non-exhaustive list of other areas to change
would be:

• Estate development code – To improve the streetscapes and provision of open space
in new suburbs

• Lease variation charges – These could be varied to support exemplary developments,

in particular more affordable and environmentally sustainable developments.

• EER - The current EER system seems to be creating dwelling units that will not be
habitable in very hot weather without the use of air conditioning. This is especially
true of apartments which typically in Canberra are east or west facing and thus
overheat. Dwellings should be built with cross ventilation so they can be habitable in
summer even if there is an electricity failure. The EER system also needs to be
adjusted to reflect climate change as it does not use the expected future climate that

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 dwellings will have to function in. I understand that a Climate Zone 7 is proposed for
introduction to the NATHERS rating, this should be examined.

Site coverage vs plot ratio

In the following sections, we use site coverage ratio in preference to the current reliance on
plot ratio. The use of plot ratio as a primary planning control is encouraging low buildings
that fill as much of the block as possible, most notably in the RZ1 Zone. It also limits the
options for controlling development in the denser zones. For example, in the RZ2 Zone, an
80% plot ratio by itself will result in single-storey buildings that over-develop their blocks. A
40% site coverage ratio with a two storey height limit leads to the same amount of building,
but split over two levels with much more open space. I recommend that site coverage ratio
is introduced as a primary planning control in the RZ1 to RZ4 zones.

Reforming the RZ1 Zone

Fixing the overdevelopment of houses

It is clear from the above discussion that the RZ1 Zone is failing when it comes to houses.
The following changes are needed urgently to fix the over-development.

• A site coverage ratio of 40% should be introduced for all block sizes. An alternative
approach would be reducing the plot ratio to 40% for all block sizes.

• Given houses are typically built for families, private open space should be made into a
child-friendly garden instead of just a narrow front setback. This could be done by
changing the ‘principal private open space’ rules to require it to be delivered behind
the building line or a courtyard/front fence. Alternatively low front fences could be
allowed so that small children and/or pets can safely use front gardens.

Subdivision and block consolidation

Canberra’s suburbs were divided into blocks to meet the requirements of a different era.
Delivering the missing middle will often work better if we are not stuck to the existing block
boundaries. Where blocks can be consolidated and re-subdivided, it may be possible to do
better redevelopments, for example if a row of blocks can be consolidated then re-
subdivided, it may be possible to create a rear laneway to service terrace-style dwellings.
However, under the current broken rules for houses, subdivision would move existing large
house blocks into the ‘mid-sized’ and ‘compact’ categories. The practical result would be
the complete and permanent removal of all trees and a potential quadrupling of the amount
of building on many blocks, from one existing smaller, older house of 100-150m2 to two new
houses of 250m2 each.
If the existing problems with the RZ1 Zone are fixed, sensible site coverage ratios are in
place to protect open space, and controls are also in place to make room for trees, I would
support allowing block consolidation and subdivision.

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Dual occupancies
Dual occupancies are a useful form of ‘missing middle’ housing, particularly for families
looking for an affordable option and older people looking for a stairs-free home with less
garden to maintain. However, they have drawbacks. Front-and-back dual occupancies in
particular require unit-titling and come with a large amount of driveway space that is
unattractive, reduces space for vegetation and contributes to the heat island effect. Side-
by-side dual occupancies have fewer problems, but still need to be handled carefully.
I would support reforming the rules for dual occupancies in the RZ1 Zone to make them a
viable option, provided the result is not over-development without sufficient useable open
space and room for trees. A workable option could be as follows:
1. Use the same 40% site coverage ratio for all development in the zone, including dual
occupancies
2. Bring all RZ1 blocks in line with a 600m2 minimum size for dual occupancy
3. Allow unit-titling
4. Allow common parking areas of both units to reduce space covered by driveways
Allowing dual occupancies that meet the existing broken rules for houses would not be
acceptable to the majority of the community.
Also note that multiple occupancies (e.g. 3 per block) may be considered on very large
blocks or for high-quality ‘tiny-houses’, but this would need to be explored carefully with
the community.

Reforming the RZ2 Zone

The RZ2 Zone was intended to provide a mix of small houses, duplexes, terraces,
townhouses and apartments in each neighbourhood. It is typically located close to shops
and major transport nodes so as to provide an opportunity for more people to live in these
areas with additional amenity and connectivity. It also provides for people who want to live
in a suburban style environment but don’t want or can’t afford a single house on a block.
This includes:

• Young people who want an apartment with minimal household upkeep

• Busy people who don’t want a lot of household and garden maintenance

• Older people who want to downsize but stay in their current neighbourhood

• Families (especially small families which are now common), looking for a more-
affordable or more-compact option.
Sadly, the RZ2 Zone has failed to deliver in most areas. The rate of development has been
slow, much of the development has been large single houses, quality has been lacking and
conflict with neighbours has been high in some suburbs. Reform is required that balances

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better protection for existing neighbourhoods with more flexibility for infill. This could
include:

• Introducing a common site coverage ratio of 50% for all denser development types to
help ensure developments retain open space and a suburban feel. If we stay with plot
ratio only, it will need to be reduced from current levels to achieve the same affect.

• Removing low-benefit restrictive rules (e.g. dwelling replacement) and allowing

apartments in developments that provide a diversity of housing

• Introducing strong disincentives for building large houses instead of the medium-
density the zone is intended for.
The Discussion Paper raises the possibility of “increasing the permitted density of
development on a block in RZ2 zones”. If by this the paper is considering a greater number
of households within a block but the dwelling units are smaller, this on the face of it is a
good idea. If the suggestion is only to increase the amount of building, but not the number
of dwellings, this is not acceptable.

Making room for trees: RZ1 to RZ4 Zones

To overcome the loss of existing trees and permanent ‘building out’ of room for vegetation,
all four zones covered by the Discussion Paper need to have planning controls introduced to
protect part of each block for trees and permeable surfaces.
This issue could be dealt with in the Territory Plan by introducing a mandated percentage of
each block not to be covered by the building footprint or hard surfaces. This would be an
additional rule to the site coverage and/or plot ratios relating to building size so that the
space put aside is of suitable dimensions for canopy trees and fully permeable (excludes
sheds, ‘alfresco’ areas and driveways). A supporting criteria could allow reductions in size
where existing vegetation is to be retained.
It has sometimes been argued that this sort of measure is futile as ACTPLA would be unable
to stop landowners from concreting over their open space, regardless of the planning rules.
I do not agree with this view. The abundance of aerial photos in recent times mean that
ACTPLA could develop an automated software tool that compares photos over time to
identify breaches. Further, examination of aerial photos shows that very few homeowners
and body corporate do pave over a large part of their green open space, even in the denser
zones. Land that is excluded from the building footprint and driveways almost always
appears to stay largely as green space.

Imporoving the RZ3 and RZ4 Zones

I agree with the Discussion Paper that development potential could be increased in the RZ3
and RZ4 Zones – but doing so for all developments would just lead to bigger poor-quality
developments. Increases in these development controls should only be available for

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development that demonstrates superior design quality or clear community benefit – see
‘Delivering better development’ section above.
The Discussion Paper also makes the following point: “Trends in recent development
applications indicate some developers are undertaking RZ2 style developments (e.g. town
houses) in RZ3 and RZ4 zones”.
I do not see terrace and town houses in RZ3 and RZ4 Zones as a problem. Rather, they are a
benefit for housing diversity overall and housing diversity in those zones. Further, there is
no shortage of land supply for apartments in Town Centres, Group Centres and the Mixed
Use Zone.
Any changes to planning controls in the RZ3 and RZ4 Zones should try not to squeeze out
terrace houses and townhouses.

Delivering better development

Incentives for higher quality and community benefit

The Territory Plan needs to incorporate incentives for better quality development. There
are several ways this could be done. For example, incentives could be provided through
better use of the Merit track and Criteria system. Many key Rules like plot ratio have no
Criteria, so there is no incentive to do better. Others like private open space provide a free-
kick for developers to be able to bend the rules. The Criteria should provide clear incentives
that are linked to clear design quality outcomes or community benefits. Below, I give an
example of how this might work for site coverage ratio, but a similar approach could be
taken for building height, open space and other key variables.

Rule
The site coverage ratio is
not more than 40%
Criteria
A higher site coverage ratio may be permitted where the
development demonstrates a clear community benefit or
high design quality, for example:
• Net Zero Emissions, Passive Haus or other
environmental certification above standard industry
practice
• Inclusion of community housing or affordable housing
accreditation such as Nightingale
• Co-design or quantified high levels of local community
support
• A co-housing development
• Substantial heritage conservation work and the
development is supported by the ACT Heritage Council
• A roof garden that is designed to last

This approach could work in all four Zones covered by the Discussion Paper.

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Affordable housing requirements
An alternative approach would be targeted incentives for the provision of affordable
housing as part of redevelopment (known in the planning literature as ‘inclusionary zoning’).
This approach would see developers who wanted to exceed the standard Territory Plan
rules and criteria either provide community housing to a registered provider or make a
monetary payment to a trust set up for this purpose. This is common practice in some other
jurisdictions, including New South Wales, and can lead to a substantial increase in the
supply of affordable housing over time.
Due to the scale of development required, this approach would probably only be practical in
the RZ3 and RZ4 Zones.

Design Review Panel

The Discussion Paper raises the possibility of using a Design Review Panel to improve the
design quality of proposals. I support this, provided the Panel is not used as an alternative
to public consultation. Public consultation is critical for transparent and accountable
decision making.

Parking requirements

The parking requirements in the Territory Plan need to be reviewed and better-adapted to
location. Currently, standard rates apply to all residential areas – which means a small three
bedroom apartment close to jobs and shops in Braddon is required to provide the same
amount of car parking (two spaces) as a large house in Canberra’s outer fringes. Census
data clearly shows that the rate of car ownership is not the same across Canberra, which
means the Territory Plan is forcing developers to provide car parking that is not needed in
inner city areas. The parking requirements are also counter to the ACT Government’s
planning, transport and climate policies.
This surplus parking has a substantial impact on affordability. Data provided by the ACT
Government recently indicates that an average basement car-parking space costs $30,000
to construct. With new 3-bedroom apartments selling from $500,000 up, each surplus
parking space is potentially adding over 5% to the dwelling cost.
Other associated changes required are:

• Allowing parking spaces to be sold separately to dwellings, so buyers can on-sell any
spaces they do not require

• Providing an incentive for developers to replace some car parking with a car-share
scheme.

• Ensuring that there is provision for electric cars to be charged.

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Waste Requirements
I have been told that in many multiunit developments, the waste storage and removal
requirements are a major design factor. The ACT government should explore waste
collection vehicles that are more agile so as to reduce the lost space. Vehicles also need to
the smaller so as to reduce the requirement for 7m clearance on the ground floor to
accommodate waste vehicles.
In the absence of a government scheme to enable processing of organic waste, multi-unit
developments should be required to make their own provision for either on-site processing
or transport to an appropriate processing facility.

Notes
Heritage
Note that in the above discussion, I am not intending that heritage protection be
undermined. Changes to the RZ1 Zone in particular will impact on Canberra’s heritage
housing precincts. Specific carve-outs may be needed for these precincts, for example
through overlays or additions to the precinct codes.

Solar access
Further note that in the above discussion, I am not intending that the current rules for solar
access should be relaxed. I would not support any relaxation of these rules. In fact, many of
the difficulties with implementing the current rules would be resolved by not permitting
new dwellings that almost-entirely fill blocks in the RZ1 and RZ2 Zone as each block would
have more unroofed space for sunlight to reach windows and private open space.

RESPONSES TO OTHER ‘CONVERSATION STARTERS’

This section responds to the Discussion Paper’s ‘Conversation Starters’, where they are not
addressed above.

Reviewing the definition of ‘apartments’ for the benefit of the RZ2 zone

I do not support this as it would be simpler to allow some apartments as currently defined –
see RZ2 discussion above.

Amalgamation of the RZ3 and RZ4 areas into a single zone

I do not support this proposal for the following reasons:

• The RZ3 Zone is providing more townhouses than the RZ4 Zone, and as mentioned
above I see this as a benefit for housing diversity

• The RZ3 Zone is a less-intrusive redevelopment zone than the RZ4 Zone. It was
specifically designed as a transition zone between suburban areas and redevelopment
areas. This role is potentially useful in future as we still have a large number of

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 locations (e.g. around Town Centres and universities) where there is very little
transition from high-rise buildings and dense activity to suburban homes.

Location of zones

The Discussion Paper raises the possibility of using the Housing Choices process to rezone
some areas. I do not support this.
I agree that there are many opportunities for changing which zone applies where. For
example, there are a number of RZ1 and RZ2 Zone areas close to major centres and
universities that could be upgraded to the RZ3 Zone. There are also local centres that would
benefit from the addition of shop-top housing or work-at-home terraces and this could be
done through upgrading from the RZ2 Zone to the Mixed Use Zone.
However, some of these rezoning opportunities will prove to be highly-controversial in
practice. Others will require adapting the standard planning controls to each local area
through additions to the local Precinct Code. The community will also find it difficult to trust
a rezoning process where the rules of the zones involved are in the process of changing. It
will conflate the arguments for the types of housing and housing rules being explored and
proposed with area-specific proposals.
I therefore believe that the Housing Choices process examining the types of housing to be
developed in which zones should be kept separate from processes that propose rezoning.

Thank you again for this opportunity to comment on the future of our residential zones. If
you have any questions about this submission, I can be contacted on (02) 6205 1941.
Yours sincerely

Caroline Le Couteur MLA

ACT Greens Member for Murrumbidgee

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