Additional comments from Senator David Pocock

Additional comments from Senator David Pocock

Opening Remarks

1.1I thank the Chair, Deputy-Chair, Committee members and the Secretariat for their work over the last 13 months and the attention they have given our National Capital. This inquiry offers a vital opportunity to present an ambitious vision capable of setting Canberra up for the future. The ACT is predicted to be home to half a million people by 2027, with an anticipated growth rate over the next three years that is higher than any other state or territory.[1] Yet, despite Canberra’s growth and unique status as the nation’s capital, the city has suffered decades of neglect and underinvestment.

1.2As well as serving as our capital, Canberra is a regional hub servicing another half a million people from across the border. This is also often forgotten given Canberra’s unique geographical position as an enclave within New South Wales. It is the only capital city whose population is not counted to include surrounding spillover towns as part of ‘Greater Canberra’, further exacerbating the relative underspend on the territory’s infrastructure.

1.3The ACT is the only state or territory not to have signed one of the former Coalition Government’s City or Regional Deals, which include almost $10 billion in dedicated Commonwealth funding. Some jurisdictions signed two or three such deals.

1.4How can it be the case that our National Capital was not party to one of these deals, vital to forward-looking infrastructure planning, multi-governmental coordination and major investment decisions for key cities across our country?

1.5Perhaps as a consequence of being forgotten by the Australian Government, Canberra remains the least-known capital city in the developed world. My conversations with people across the community I represent indicate that Canberrans are tired of people punching down on Canberra. It is time to foster and promote Canberra’s status as Australia’s National Capital, which is why I thank the Joint Standing Committee on the National Capital and External Territories for its consideration of this matter.

1.6We need to rectify the historic underinvestment in the ACT in order to elevate Canberra’s status as our capital and set this city up for the future.

1.7This inquiry heard evidence from a diverse range of witnesses providing testimony in favour of key investments that can shape our National Capital into a place in which Australians can be proud. The recommendations presented in the main Committee report are a step in the right direction but far more ambition is both possible and warranted in light of the evidence provided to this inquiry.

1.8These additional comments are informed, also, by my direct and ongoing consultation with Canberrans and leading organisations representing businesses and community members across the ACT who want more for our National Capital.

The City to the Lake Vision

1.9It has never made sense for Canberra’s City Centre to have its back turned on Lake Burley Griffin. Canberra is one of a handful of planned cities globally and is the largest Garden City in the world. Visionary design and planning work by Walter Burley and Marion Mahony Griffin emphasised the integration of natural landscapes, geometric patterns and community assets, shaping Canberra into the ‘Bush Capital’. The Lake is the stunning centrepiece around which Canberra was designed. It should not be separated from the city by a four-lane dual carriageway, which is why Parkes Way was not part of Walter Burley and Marion Mahony Griffin’s plan for Canberra.

1.10The ACT Government’s 2014 City Plan aimed to address this problem including, in Greater Canberra’s words, by “undoing the mistake that is Parkes Way”.[2]

… in 2014 the City Plan was released as a joint initiative between the ACT Government and Australian Government and utilises the Griffin legacy to provide the underlying blueprint and soul of the city – the ACT’s primary municipal centre.[3]

1.11The 2014 City Plan laid out an ambitious City to the Lake vision capable of transforming the corridor between Canberra’s City Centre and Lake Burley Griffin. This vision builds upon the Griffin Legacy, referenced by six submitters to the inquiry, by improving connectivity between the National Triangle and the City Centre, thereby increasing the integration of Canberra as our National Capital and Canberra as a thriving city in its own right.

1.12Central to the City to the Lake vision was significant works to the four-lane dual carriageway separating the City from the Lake; namely, Parkes Way. The works would transform Parkes Way into a partially lowered, ‘smart boulevard’, thereby increasing walkability through the southern end of Civic. Not only would these works create space for a new convention centre and stadium in the City Centre, but they would also unlock land for desperately needed housing in a convenient, well-serviced location.

1.13Canberra is the second most expensive Australian city in which to rent and buy a home. The ACT’s rates of persistent homelessness are almost twice the national average. The National Capital should be able to provide secure housing for all its residents. According to the original City to the Lake vision, thousands of new dwellings could be unlocked by carrying out the Parkes Way works.

Key to this vision is undoing the mistake that is Parkes Way – preferably by burying Parkes Way completely. Burying Parkes Way would fulfil the Griffin vision for Lake Burley Griffin to truly become Canberra’s playground, and will unlock access to Commonwealth Park. It would also make northside national institutions, such as the Australian War Memorial (potentially in conjunction with changing the nature of Anzac Parade), more integrated with the Lake and the city as a whole.[4]

1.14In response to a question on notice regarding the 2014 City Plan, which incorporates the original City to the Lake vision, the ACT Government provided evidence that:

The 2014 document was not explicit on physical connections between the City Centre and the Lake largely due to the physical barrier of Parkes Way… [5]

1.15The Committee should note the inaccuracy of this evidence. The document referenced is quite explicit about physical connections between the City and Centre and the Lake, containing at least 25 specific mentions of Parkes Way, including:

Parkes Way will operate as a ‘smart boulevard’ that will deliver an upper level street network for city centre access with a clear transit route for east-west traffic at a lower level.[6]

Lowering Parkes Way as part of the City to the Lake project will deliver improved pedestrian links into West Basin and Commonwealth Park.[7]

The proposal for Parkes Way to become a ‘smart boulevard’ that both channels through-traffic and allows for pedestrian connectivity at ground level is a central element of the City to the Lake proposal.[8]

1.16Like the 2014 City Plan, the NCA acknowledged the barrier presented by Parkes Way in its evidence to the inquiry:

The NCA recognises that Parkes Way is a potential impediment to easy access between the northern edge of the National Triangle and Lake Burley Griffin.[9]

1.17Greater Canberra’s fourth recommendation is to deliver the City to the Lake vision in full, supported by Commonwealth funding and planning approvals.

Recommendation 1

1.18That the Commonwealth Government invest in the completion of the original City to the Lake vision, as presented in the ACT Government’s 2014 City Plan, to increase connectivity between the City Centre and Lake Burley Griffin, unlock land for much-needed housing and present space for Canberra’s new convention centre and stadium to be optimally located.

A New National Convention Centre

1.19The need for a new convention centre in Canberra was identified as early as 2001, when the 17th Commonwealth Heads of Governments Meeting was relocated from Canberra to Brisbane due to the insufficiency of our local facilities. Former ACT Chief Minister Jon Stanhope called for a new, federally funded convention centre in 2008, leading to extensive planning and design work from 2010 to 2015 on a proposed ‘Australia Forum’ to be constructed in Civic. But this project never came to fruition.

1.20The Australian Government has indicated a desire to host the Conference of the Parties (COP). We should be able to host COP in the National Capital. The National Convention Centre is insufficient with a 2,000-square-metre exhibition space paling in comparison with Sydney’s and Melbourne’s 30,000-square-metre spaces.

1.21While the main Committee report recommends “the development of the National Convention Centre”, a full rebuild is needed. The main Committee report notes evidence from Mr Matthews of the Canberra Convention Bureau recommending an exhibition space of at least 10,000 square metres is required. This is not feasible on the current site, indicating a new convention centre on a new site is needed to satisfy the National Capital’s requirements.

1.22The Parkes Way works recommended above would create additional space in the city-to-lake corridor for a suitably sized National Convention Centre in Civic.

Recommendation 2

1.23That the Commonwealth Government invest in the construction of a new National Convention Centre with an exhibition space of least 10,000 square metres capable of servicing Canberra’s current and future needs as Australia’s meeting place.

A New, Optimally Located Stadium

1.24While the main Committee report recommends ‘upgrading’ Canberra’s stadium infrastructure, the evidence provided to the inquiry overwhelmingly indicated that a new stadium is needed.

1.25The Australian Professional Leagues (APL) expressed concern that redeveloping the existing stadium would lead to disruptions creating “an enormous challenge to the establishment and ongoing sustainability” of the new men’s A-Leagues club that the APL is seeking to bring to Canberra. The APL expressed support for a new stadium with capacity of 15,000 to 25,000 seats that is “centrally located”, “well connected in terms of roads and public transport” and “convenient to other hospitality businesses (such as restaurants, bars, cafes and hotels)”.[10]

1.26The NRL indicated strong support for a stadium in Civic, stating that a new 30,000-seat stadium in Civic would be capable of attracting major rugby league events “such as Indigenous All Stars and Internationals, Test Matches and Women’s State of Origin.”[11] In its submission, the NRL stated clearly that a “national stadium that showcases national significance should be located in a central business district.”[12]

1.27The Convention Centre Bureau submitted evidence indicating that co-locating the new convention centre with the new stadium “would deliver significant advantages”.[13]

1.28The Canberra Business Chamber also provided evidence in support of revisiting previous proposals “combining a new stadium and a new convention centre”, stating that co-locating the two venues “could result in the development of an entertainment and hotel precinct that could reinvigorate Civic”.[14]

1.29While one witness indicated support for a centrally located stadium at Exhibition Park and three submissions favoured a stadium in Bruce, including that provided by the ACT Government, insufficient evidence was provided to support the main Committee report’s conclusion that “any new stadium would now only be built in Bruce.” The purpose of this inquiry is to report on ways to foster and promote the significance of Australia’s National Capital, including through consideration of future infrastructure needs. The evidence provided by current and prospective users of the stadium and convention centre – as well as that provided by the Canberra Business Chamber on behalf of the National Capital’s business community – clearly indicates that the future infrastructure needs of our National Capital include a centrally located stadium co-located with a convention centre, both of which could be supported in Civic by a thriving hospitality precinct.

1.30Co-locating the two facilities would maximise the efficiency of both, boosting the economic return on the investment in their construction. If closely situated to one another, the two venues would be able to share some back-of-house facilities, parking and staffing, forming a combined precinct serviced by a new suite of hotels, restaurants and bars with substantial surge capacity for when major events come to the National Capital.

1.31The stadium could be partially roofed to support not only Canberra’s proud local sporting teams but also national sporting events and major touring music acts. If designed innovatively and with an eye to the future, a new entertainment precinct in the City Centre headlined by a new National Convention Centre and National Stadium would maximise economic efficiency while significantly elevating Canberra’s status as our National Capital.

1.32The Stage 88 upgrades recommended by the main Committee report can signal the beginning of an ambitious redevelopment of Commonwealth Park that, combined with the Parkes Way works and the new National Convention Centre and National Stadium, will create a modern entertainment precinct spanning the city-to-lake corridor. This precinct will boost amenity for locals while giving the National Capital great appeal as an emerging global tourist destination. It will also create opportunities for major music festivals making use of the new National Stadium as a main stage and the redeveloped Stage 88 facility as a secondary stage, with attendees able to move freely between the two stages on foot courtesy of the lowering of Parkes Way.

1.33To maximise the value of these infrastructure investments, they need to be supported by modernised sound laws capable of transforming the National Capital’s night-time economy. Canberra’s sound laws are outdated and put a handbrake on major events in and around the CBD. Regulatory reform is needed to release the handbrake and fully activate the city-to-lake corridor. Given this new precinct will traverse both territory and national land, these regulatory and infrastructural improvements need to be implemented through proactive, forward-looking collaboration between the NCA and the ACT Government.

Recommendation 3

1.34That the Commonwealth Government invest in the construction of a new National Stadium co-located in Civic with the new National Convention Centre, and that the NCA work collaboratively with the ACT Government to modernise sound laws in the National Capital.

A New Civic Pool

1.35A new aquatic facility in the City Centre was identified as a high priority of need by the ACT Government in 2013.[15] Civic Pool is ageing and “has been expensive to maintain in recent years”;[16] repair works would extend its life only briefly. The main Committee report rightly recommends upgrading Stage 88 in Commonwealth Park. Civic Pool’s iconic 10-metre diving board is part of our capital’s history and could be relocated to a new Civic Pool in Commonwealth Park with views to the beautiful Brindabellas. The NCA provided evidence indicating this is possible:

The National Capital Plan identifies Commonwealth Park as an area to be generally available for public recreation. A preliminary desktop assessment of the park (by NCA) suggests the park may be able to accommodate a public swimming pool.[17]

1.36According to a 2022 Royal Life Saving report, the ACT received $0 of the combined $316.5 million in Commonwealth funding delivered and committed for aquatic facilities across Australia from 2017 to 2022.[18] This is another example of the Australian Government’s neglect of the National Capital; an imbalance that can be rectified by funding the long-overdue construction of a new pool in Commonwealth Park. The Parkes Way works recommended above will also significantly increase the accessibility of the new Civic Pool, particularly for pedestrians and cyclists.

Recommendation 4

1.37That the Commonwealth Government invest in the construction of a new Civic Pool in Commonwealth Park.

Repeal the Efficiency Dividend for National Cultural Institutions

1.38Evidence was provided to the inquiry indicating the negative impact of the efficiency dividend on the operations of the National Cultural Institutions (NCIs).

1.39The National Capital Educational Tourism Project submitted that the budget cuts and efficiency dividends suffered by the NCIs “have directly resulted in a reduction of staff and resources”, correlating this with the extent to which “students are able to connect directly with stories told at these places.”[19] The submitter also pointed to failed attempts to protect school programs from the impacts of these budgetary pressures.

1.40The National Capital Attractions Association expressed a similar concern, submitting in support of measures to address “the disproportionate impact of the efficiency dividend on NCIs” on the basis that:

Successive efficiency dividends over the years have had a devastating effect on the capability of NCIs to deliver what governments have asked them to.[20]

1.41While the main Committee report recommends increased funding for marketing to promote digital access to National collections and core funding to the National Institutions for touring exhibitions, it fails to address the disastrous effects of the efficiency dividend on the sustainability of our National Cultural Institutions, which, in many ways, are the beating heart of our National Capital.

1.42The efficiency dividend, while designed to ensure large departments are constantly looking for ways to operate more efficiently, has significantly hindered the operations of our National Cultural Institutions, their staff, their collections and their long-term viability as an asset and source of pride for all Australians. It is time to recommit to our National Cultural Institutions and exempt them from the efficiency dividend.

Recommendation 5

1.43That the Commonwealth Government remove the efficiency dividend for all our National Cultural Institutions.

Revenue for the NCA

1.44The main Committee report makes various recommendations regarding expanding the role of the National Capital Authority but does not propose additional funding to support the NCA to enhance its existing work. The NCA is responsible for managing land and assets that are vital to the National Capital including Commonwealth Park, Stage 88 therein, Stirling Park (Gurubang Dhawura) and Lake Burley Griffin.

1.45As the Bush Capital, the beauty of Canberra’s natural environment is a key part of the National Capital’s story and legacy. The main Committee report makes reference to evidence provided by the Friends of Grasslands that the NCA’s limited budget has resulted in limited investment in the maintenance and restoration of national land. The NCA needs increased funding to support the management of the capital’s natural landscape, as well as the built assets it contains.

1.46Despite land within the National Triangle being managed by the NCA, public parking fees on this land are returned to consolidated revenue. Allowing the NCA to keep revenue from parking fees on its land would provide the funding boost needed to address concerns raised by the Friends of Grasslands. The National Capital Attractions Association spoke in support of a similar idea:

… much as the United Kingdom’s National Lottery provides grants for museums, libraries and cultural organisations, an alternative source of revenue to fund cultural developments in the Parliamentary Triangle and elsewhere should be made available to NCIs – for instance, all revenue collected from public parking fees could be directed to a centralised grants program focussed on NCIs.[21]

1.47Although the Association’s proposed use of the funds is different, the proposed mechanism for increasing revenue is the same.

Recommendation 6

1.48That the NCA be given all parking revenue generated on the national land for which it is responsible, and that this additional revenue be used for the purposes of maintaining and restoring that land and the built assets it contains.

Fair Representation for Cricket ACT

1.49Cricket ACT provided evidence suggesting that its unequal representation in the governance structure of Cricket Australia has disadvantaged the National Capital in various ways, including by limiting the growth of both community and elite cricket in Canberra despite high demand and high relative participation rates and by failing to provide young cricketers wishing to transition from community cricket to the elite level with a complete pathway to do so in the National Capital.

Unlike National Cabinet whereby all States and Territories are equally represented, Cricket Australia has six members (shareholders) which are the six States. The Territories (ACT and NT) are non-member associates with no voting rights, no representation on the Cricket Australia Board and no formal recognition in Cricket Australia’s current constitution.[22]

1.50The main Committee report acknowledges the inequity of Cricket Australia’s governance structure. I support the Committee’s comments calling for “the inclusion of Cricket ACT and NT Cricket as member associations of Cricket Australia consistent with the six state associations, and for Cricket ACT and NT Cricket to be similarly represented by a Director on the Cricket Australia Board.” Sufficient pressure must be applied to Cricket Australia, however, to ensure these changes are made. A formal recommendation is warranted.

Recommendation 7

1.51That the Commonwealth Government request Cricket Australia update its governance structure and the composition of its board to match the rights and representation of the territories to those of the states.

Commit to a Home of Football for the National Capital

1.52A Home of Football for the National Capital was first announced in 2019, with Capital Football and the ACT Government committing to a co-investment of $33.5 million for the construction of a facility including five open-air playing fields, an indoor futsal facility, offices, extensive parking, a grandstand and more. This facility was to be a boon for soccer in Canberra at both a community and professional level. Its construction has been delayed, however, and projected costs have since blown out to $50 million due both to higher construction costs and the dollar value of the initial funding commitments having been diminished by inflation more generally. An additional $18.75 million is now needed to complete the project as originally planned.

1.53With the increased soccer participation rates for women and girls precipitated by the success of the Matildas in the 2023 FIFA Women’s World Cup, now is the time to commit to the ACT Home of Football. An investment from the Commonwealth is required to ensure and expedite the construction of this asset in full, which is vital to fulfilling the National Capital’s long-term infrastructure needs.

1.54The APL provided evidence indicating it is considering the Home of Football as a training facility for a potential men’s A-League team in the National Capital.[23] The ACT Government also spoke of the “strong demand for community sporting infrastructure”, stated that “the ACT has not received the level of federal investment into community level infrastructure as other jurisdictions” and used the Home of Football as an example where the ACT Government “is the sole government investor” while “similar projects in Western Australia, NSW and Victoria have been significantly enhanced through federal investment.”[24] Indeed, Victoria and Western Australia received $15 million and $16 million respectively from the federal government for similar ‘Home of Football’ projects.

1.55Canberrans deserve to see this project go ahead to ensure soccer can continue to thrive in the National Capital while supporting the growth of women’s soccer at the community and elite levels. It is time to commit to the ACT’s Home of Football with a co-investment from the Commonwealth Government.

Recommendation 8

1.56That the Commonwealth Government co-invest with the ACT Government in a Home of Football for the National Capital by contributing the remaining $18.75 million needed to complete the project as originally planned.

Invest in Lake Burley Griffin

1.57Lake Burley Griffin is the stunning centrepiece around which the National Capital was planned and constructed. The quality of water in the Lake is key to the prosperity and vitality of the National Triangle. Many submitters provided evidence in support of protecting or enhancing the Lake, most notably the Reid Residents’ Association,[25] the Lake Burley Griffin Guardians,[26] and, above all, the NCA:

Supporting this vision [of a full lake loop walk] would be measures to improve lake water quality. This would be achieved by working with the ACT and NSW Governments to improve the quality of water flowing into the Lake. This would require capital investment to build stormwater pollution control ponds and wetlands at points where stormwater flows into the lake or adjacent sections of the Molonglo River.[27]

1.58While the NCA is responsible for the water in the lake, it provided evidence indicating that the quality of that water “is highly dependent on the quality of water flowing into the Lake from the catchment.”[28] The quality of the water flowing into the Lake is largely a consequence of water management on the part of the ACT Government.

Between 2017 to 2019, the ACT Government constructed two wetlands and conducted extensive riparian restoration to help improve the quality of water entering Lake Burley Griffin. These projects were part of a joint ACT-Commonwealth investment in the ACT Healthy Waterways program. Since 2020, the ACT Government has continued funding the next stage of the Healthy Waterways program, which includes research into how Lake Burley Griffin responds to inputs of nutrients for algal blooms and the development of a catchment plan for managing water quality entering the lake.[29]

1.59Given the ACT’s relatively low revenue base, the importance of the Lake to the National Triangle, and the importance of water quality to the Lake’s health and attractiveness, it makes sense for the Commonwealth Government to invest in supporting the ACT Government’s efforts to improve the quality of water flowing into the Lake. Taking every opportunity to convert existing concrete storm water systems across the ACT into water-cleaning, naturalised wetlands needs to be a priority for both levels of government.

1.60In its evidence to the inquiry, the ACT Government indicated that recommendations contained in a catchment plan to be released in early 2025 will inform “ongoing investments to improve water quality in the Lake Burley Griffin catchment”.[30] The Commonwealth Government should support the recommendations of that catchment plan with federal funding commensurate with the importance of Lake Burley Griffin to the status of the National Capital and to the appeal of the key National Institutions surrounding the Lake.

Recommendation 9

1.61That the Commonwealth Government provide additional funding to the ACT Government to support its efforts in improving the quality of water flowing into Lake Burley Griffin, including by replacing the concrete stormwater systems with naturalised creeks and wetlands.

Comments on the Conduct of the Inquiry

1.62I thank the many groups, organisations and individuals who made submissions and appeared at hearings that were part of this inquiry. Given the opportunity this inquiry presented to make a strong case for investment in major infrastructure projects for the National Capital, it was disappointing that the ACT Government refused to answer many questions on notice that were relevant to the Terms of Reference. Of 31 written questions on notice sent to the ACT Government following its appearance at the hearing, only seven received a response.

1.63On 27 February 2024, the Chair of the Committee wrote back to the ACT Government requesting responses to a reduced list of 11 outstanding questions, providing a deadline of COB on 12 March 2024. No response had been received at the time of tabling of this report.

1.64While I acknowledge the Senate cannot compel State and Territory governments to provide evidence to committees, it should not have to, and not responding after the Chair of a committee requests a response shows a concerning disregard, or even contempt, towards the Committee’s work. This inquiry offers an opportunity for the Commonwealth to show ambition and long-term vision in investing in Canberra as our National Capital. This was an opportunity the ACT Government could have chosen to grasp to the greatest extent possible. It is disappointing that the government of the jurisdiction in which our National Capital resides chose to leave relevant questions unanswered.

1.65Further, as mentioned above, the ACT Government provided incomplete evidence regarding plans central to the future of the National Capital, published by the ACT Government a decade ago, that have not been implemented. Transformative works to Parkes Way were ‘central’ to the City to the Lake vision outlined in the 2014 City Plan, according to page 118 of the plan itself. But in response to a question on notice regarding that plan, the ACT Government stated that the “document was not explicit on physical connections between the City Centre and the Lake” but that “a corridor study on Parkes Way is noted under the broadly headlined ‘City to the Lake’ on page 123.” This evidence unreasonably diminishes the centrality of the Parkes Way works to the 2014 City Plan and could reasonably be interpreted as misleading. It is unclear why this evidence was provided to the committee given it contradicts the ACT Government’s publicly available documents.

Concluding Remarks

1.66This inquiry has unearthed significant and widespread need for increased investment in the National Capital on the part of the Commonwealth Government. The Commonwealth has an obligation to address this need and an opportunity to act with ambition in response to the findings of this inquiry and these additional comments. It is time for both levels of government to work together to elevate Canberra’s status as an international city and set this unique place up for a prosperous future that makes all Australians proud to call Canberra our nation’s capital.

Senator David Pocock

Independent Senator for the Australian Capital Territory

Footnotes

[1] See https://population.gov.au/data-and-forecasts/dashboards/state-and-territory-projections.

[2] Greater Canberra, Sub013.

[3] ACT Government, Sub037.

[4] Greater Canberra Inc., Sub013.

[5] ACT Government, SupSub037.2.

[6] ACT Government, 2014 City Plan, p. 86.

[7] Ibid., p. 91.

[8] Ibid., p. 118, emphasis added.

[9] NCA, SupSub033.1.

[10] Australian Professional Leagues, Sub043.

[11] National Rugby League, SupSub009.1.

[12] National Rugby League, Sub009.

[13] Canberra Convention Bureau, SupSub007.1.

[14] Canberra Business Chamber, Sub018.

[15] See https://issuu.com/wvcc/docs/final-report.

[16] Mr Greg Blood, Sub001.

[17] NCA, SupSub033.1.

[18]See www.royallifesaving.com.au/__data/assets/pdf_file/0004/69385/RLS_AquaticInfrastructureReport2022.pdf

[19] National Capital Educational Tourism Project, Sub038.

[20] National Capital Attractions Association, Sub035.

[21] National Capital Attractions Association, Sub035.

[22] Cricket ACT, SupSub014.2.

[23] Australian Professional Leagues, Sub043.

[24] ACT Government, Sub037.

[25] Reid Residents’ Association, Sub040.

[26] Lake Burley Griffin Guardians, Sub019.

[27] NCA, Sub033.

[28] NCA, SupSub033.1.

[29] ACT Government, SupSub037.2.

[30] Ibid.