Armstrong Creek Town Centre - Greater Geelong Planning Scheme Amendment C267

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1 Armstrong Creek Town Centre - Greater Geelong Planning Scheme Amendment C267 CG Prepared for City of Greater Geelong 29 October 2013

2 Document Information Prepared for Project Name File Reference Job Reference City of Greater Geelong Armstrong Creek Town Centre Greater Geelong Planning Scheme Amendment C267 CG130727PAN001F01.docx CG Date 29 October 2013 Contact Information Cardno Victoria Pty Ltd Trading as Cardno ABN Oxford Street, Collingwood Victoria 3066 Australia Telephone: (03) Facsimile: (03) International: victoria@cardno.com.au Document Control Version Date Author Author Initials Reviewer F01 29/10/13 Chris Butler Aaron Walley Reviewer Initials Cardno. Copyright in the whole and every part of this document belongs to Cardno and may not be used, sold, transferred, copied or reproduced in whole or in part in any manner or form or in or on any media to any person other than by agreement with Cardno. This document is produced by Cardno solely for the benefit and use by the client in accordance with the terms of the engagement. Cardno does not and shall not assume any responsibility or liability whatsoever to any third party arising out of any use or reliance by any third party on the content of this document. 29 October 2013 Cardno ii

3 Table of Contents 1 Introduction 4 2 Background 5 3 Response to Submissions ERM on Behalf of Coles Site Access Fabcot (Woolworths) Interim Bus Interchange Mesh on Behalf of Villawood Properties Timing of Intersections Parking Street Cross Section Widening for Surf Coast Highway (Boulevard) TGM and T&TS on behalf of the Geelong Lutheran College Department of Transport Public Transport Vic Roads Kings Lawyers on behalf of 388 Boundary Road 11 4 Conclusion 12 Appendices Appendix A Qualifications and Expertise Appendix B Cirriculum Vitae Figures Figure 3-1 Interim Bus Interchange Concept Layout 7 Figure 3-2 Parking Street Example Malop Street Geelong, East of Swanston Street 9 Figure 3-3 Parking Street Example Brougham Street Geelong, West of Yarra Street 9 29 October 2013 Cardno iii

4 1 Introduction My firm prepared the specialist report titled Armstrong Creek Town Centre Movement and Access Technical Background Report dated 10th December 2012, with this report being one of the technical documents prepared that support the exhibited Armstrong Creek Town Centre Precinct Structure Plan. I adopt this report in combination with this document as my Statement of Expert Evidence for the purposes of the Panel of Inquiry convened to consider Amendment C267 to the Greater Geelong Planning Scheme. Appendix A contains a statement setting out my qualifications and experience, and other matters raised by Planning Panels Victoria Guidelines No 1 Expert Evidence. Appendix B includes a copy of my CV. 29 October 2013 Cardno 4

5 2 Background My firm was engaged by the City of Greater Geelong in November 2011 to provide specialist traffic and transport advice as part of the consultant project team engaged to develop the Armstrong Creek Town Centre Precinct Structure Plan (ACTC PSP). The development of the ACTC PSP built on the earlier framework for the Armstrong Creek Major Activity Centre Enquiry by Design process 1 that set out the desired urban design principals and urban framework of the ACTC, including: > Identifying the preferred location of various land uses and target densities, including the location of the retail core; > Identifying the access strategy to Surf Coast Highway (including setting the location of the four key signalised intersections, coordinated with the West PSP, and identifying the preferred service road arrangements); > Setting a grid road network structure within the ACTC PSP area that includes; - Four key east-west road links across the ACTC (including Boundary Road and Burvilles Road); - Two key north-south road links across the ACTC connecting Boundary Road to Burvilles Road; - The location and alignment of the transit corridor and preferred location of an ultimate transit interchange; and - The principals behind development within the retail core including rear of centre car parking, the parking street concept, and identifying Main Street as a traditional active retail shopping street. Following numerous workshops, stakeholder engagement and specialist consultant input, the ACMAC EBD urban framework was refined to the current and exhibited ACTC PSP. Within this process my firm undertook traffic modelling to inform and support the final road network, road cross section requirements and internal and external intersection configurations. As outlined within Section 8 of the Armstrong Creek Town Centre Movement and Access Technical Background Report, traffic modelling undertaken by my firm adopted the accepted traffic generation and distribution principals applied in earlier work undertaken by my firm for the Armstrong Creek East Precinct Structure Plan 2 and was coordinated with the work undertaken by GTA Consultants for the West Precinct PSP and ongoing work undertaken by my firm for the Horseshoe Bend PSP area. This traffic modelling found that: > Road cross sections adopted within the ACTC PSP are consistent with expected street functions and desired operational characteristics, with expected traffic volumes able to be satisfactorily accommodated; > Ultimate external intersections to Surf Coast Boulevard (adopting the ultimate 6 lane Surf Coast Boulevard cross section) will have sufficient capacity to cater for expected ultimate turning movements; and > That the upgrade of Surf Coast Boulevard from 4 lanes to 6 lanes would be required at approximately 70 percent of development within the ACUGA area or 2023 based on the aspirational full development of the ACUGP area by My firm also assisted in discussions with VicRoad and Public Transport Victoria (PTV), provided technical design advice for key internal intersections, road cross sections and the interim bus interchange (in consultation with PTV and CoGG) and provided advice on appropriate parking rates and mechanisms to inform the proposed parking overlay. 1 Armstrong Creek Major Activity Centre, Enquiry by Design Report, City of Greater Geelong, September October 2013 Cardno 5

6 3 Response to Submissions I have reviewed the relevant submissions to the Planning Scheme Amendment C267, from ERM Consultants on behalf of Coles, Woolworths, Mesh on behalf of Villawood Properties, TGM (and T&TS) on behalf of the Geelong Lutheran College, the Department of Transport and Kings Lawyers on behalf of owners of 388 Boundary Road and respond as follows. 3.1 ERM on Behalf of Coles Site Access Item 2.4 refers to a potential right-turn access into the east-west parking street from Surf Coast Boulevard, stating that: It is considered that there are significant traffic engineering, pedestrian and public realm benefits in allowing right-turn access in the parking street. It is submitted that such access will increase the through traffic capacity on the Surf Coast Highway, reduce the number of vehicles using the main street whilst also helping achieve the desired pedestrian priority in the town core. In addition, it is noted that the proposed right turns would occur in the shadow of right turn movements at nearby signals, thereby retaining Council s boulevard concept, but also maintaining the highway s functionality. Surf Coast Highway (Surf Coast Boulevard within the PSP) is a State Arterial Road which is under the control and management of Vic Roads. As part of the planning of the Armstrong Creek West Precinct and Town Centre Activity Centre, Vic Roads agreed to allow four signalised intersections being Boundary Road, Connector Road B, Main Street and Burvilles Road. No other direct access has been permitted onto Surf Coast Boulevard The above intersections of Surf Coast Boulevard, including both Main Street and Burvilles Road intersections, have been designed with the capacity to cater for the projected right turn traffic flows from the south generated by the town centre without the need for a further intersection at Parking Street B. With the combination of the four signalised intersections on the Surf Coast Boulevard and the planned circulation street network grid, motorists will have ample opportunity to gain access to the retail core and intended car parking areas to the north and south of Main Street as identified in the Precinct One Concept Plan (Plan 21 within the ACTC Design Guideline). Purely considering the identified intersection spacing, sufficient separation physically exists to provide an additional median break and auxiliary right turn lane within the ultimate Surf Coast Boulevard median between the Burvilles Road and Main Street intersections. However, additional breaks within the Surf Coast Boulevard median will compromise the ability to realise the landscape outcomes for Surf Coast Boulevard identified within the ACTC PSP. Furthermore, noting the abovementioned access provisions to the ACTC, the provision of an uncontrolled right turn at the Parking Street B is unnecessary to cater for traffic movements, and in my view, provides an additional conflict point and increases the risk of accidents, particularly when the Highway traffic volumes reach the projected 40,000 to 50,000 vehicles per day in the future. Item 2.4 also requests consideration of additional access points to and from Surf Coast Boulevard service road. The provision of left-in/ left out slip lane access points along the service road to Surf Coast Highway, to service the bulky goods/ restricted retail land uses of Precincts 2 and 3. This access is vital to ensuring appropriate accessibility to these future tenancies. The service road between Main Street and Burvilles Road measures some 250 metres long. 29 October 2013 Cardno 6

7 Similar to the suggested median break as discussed above, this length would physically allow the provision of additional entry and exit treatments, but would potentially compromise the landscape objectives for Surf Coast Boulevard. If considered, an intermediate entry opening would require a give way control intersection treatment for southbound traffic in the service road providing priority to the Surf Coast Boulevard traffic entering the service road and adequate spacing between entry points is necessary to ensure that safe operation of the service lane is achievable. An intermediate exit from the service road south of the intermediate entry point would be located reasonably close to the southern exit terminal of the service lane and therefore is of less practical benefit and is less likely to be approved by VicRoads. As such, I consider that an additional service road entry could be provided, but that an intermediate exit is not practically achievable. 3.2 Fabcot (Woolworths) Interim Bus Interchange Woolworths have raised concern with the location and form of the ACTC interim bus interchange and the potential impacts for vehicle access to adjacent land from Connector Road A. The location of ACTC interim bus interchange to the north of High Street within the ACTC PSP has been determined through consultation with PTV. A concept layout plan of proposed ACTC interim bus interchange, presented as Figure 11 within the ACTC Movement and Access Technical Background Report, is shown below. Figure 3-1 Interim Bus Interchange Concept Layout N The above concept plan has been prepared to determine the additional spatial and road pavement requirements of the interim bus interchange for inclusion within the ACTC DCP, reflecting the preferred bus route planning across the Armstrong Creek Urban Growth Area (ACUGA) developed by PTV, the preferred layout and number of bays and the intended use of this interchange as a timing point. No consideration was given to individual property access, with no such information available at the relevant time. In my view, there is flexibility in the both the delivery and form of the interim bus interchange, with the potential to slide the interchange north along Connector Road A and/or split either side of the interchange around a vehicle access point if required. 29 October 2013 Cardno 7

8 Such detail would be resolved as part of the relevant town planning application and in consultation with CoGG and PTV. 3.3 Mesh on Behalf of Villawood Properties Timing of Intersections The Mesh submission states that the proposed timing of the delivery of intersections along the Surf Coast Boulevard is of critical importance to Villawood due to the shared interface along the ACTC frontage. Villawood would like to see a staging plan of the delivery of intersections and roads within the activity centre. All internal roads within the ACTC are connector or lower order roads and as such are to be developer constructed. A staging plan for the delivery of roads and intersections has not been prepared as part of the structure plan as it is considered by Council to be unenforceable and restrictive. The exhibited ACTC DCP identifies CoGG as responsible for the delivery of infrastructure identified within the DCP but allows maximum flexibility through the ability for works in kind and land-off sets in lieu of cash where agreed between the relevant parties and CoGG. In my view, this is a sensible and practical approach and allows the maximum flexibility for the provision of required road and transport infrastructure within the ACTC PSP area by allowing relevant DCP road infrastructure to be staged and provided with the associated development application. This process also allows Council to manage and respond to infrastructure requirements across the ACTC versus a prescriptive approach that would potentially result in the premature funding of works that have little benefit at that time Parking Street Cross Section The cross section of the parking streets provides a nominal 6.0 metre carriageway either side of the centre road parking. This carriageway width considers the ability of to allow vehicles to swing in and out of the centre of road parking based on a maximum 2.8 metre car parking space, with the intent to provide a reasonable balance between parking yield and the overall road cross sections. Whilst traffic lanes can be reduced to lower than 6.0 metres, this requires the widening of the centre road parking spaces to maintain access, with the resultant trade-off a decrease in the number of parking spaces. Similar parking streets exist in the CBD of Geelong (see Figure 3-2 and Figure 3-3) that have similar width carriageways and longitudinal line marking off set from the parking lane on both sides to designate a travel lane of 3.5 metres. Noting the existing treatments within the Geelong CBD, I am comfortable with the parking street cross section as proposed within the ACTC PSP design guidelines. 29 October 2013 Cardno 8

9 Figure 3-2 Parking Street Example Malop Street Geelong, East of Swanston Street Figure 3-3 Parking Street Example Brougham Street Geelong, West of Yarra Street 29 October 2013 Cardno 9

10 3.3.3 Widening for Surf Coast Highway (Boulevard) The 43.0 metre cross section of the Surf Coast Boulevard is shown Appendix 7, (PG141) of the PSP has been agreed by Vic Roads. I understand that the road reserve of the Surf Coast Boulevard varies from Burvilles Road at 43 metres to Boundary Road at 42.2 metres, with the land acquisition that has been actioned along the ACTC frontage to make a consistent 43.0 metre road reserve. This is reflected in the detailed land budget in the DCP. 3.4 TGM and T&TS on behalf of the Geelong Lutheran College The Connector A / Burvilles Road concept intersection layout has considered a fourth southern leg as an eastern access to the Geelong Lutheran College site. Whilst there is limited scope to relocate Connector Road A further east due to the location of the Transit Corridor reserve, having reviewed the T&TS functional layout plan attached to the submission, in my view there is potential to minimise any stagger within this intersection. This can be further reviewed at detailed design. As a secondary car park access point, the location of the western College access point is more flexible in my view. The exact location of this access can be determined with the College as part of the future design of Burvilles Road. However, this access should be located to avoid creating a cross intersection with a separation of at least 30 metres desirable with the ACTC Burvilles Road / High Street intersection. 3.5 Department of Transport Public Transport Public Transport Victoria does not support Cross Section 10 Main Street Town Centre Core (23.0m). The 23 metre cross section from Main Street shown in the PSP Design Guidelines provides 4.2 metre wide traffic lanes through the town centre from Surf Coast Boulevard through to Connector Road A. The 4.2 metre lane is shared with bikes. Main Street east of Connector Road A widens to 25 metres to provide 3.5 metre travel lanes and separate 1.7 metre bike lanes. PTV wish to have the separate bike lane continued through the town centre therefore widening the road reserve to 25 metres. The PTV base their decision on guidelines outlined in the GAA design guidelines and a publication Public Transport Guidelines for Land Use and Development I consider that the cross section proposed by PTV is conservatively wide and has the possibility of encouraging motorists to speed as a result of the pavement width. The target speed for this section of Main Street would be 40km/hr and although it is nominated as a bicycle route it would mainly be used by cyclists with a destination in the town centre (supplemented by bicycle routes within Parking Streets and Connector Street B) as there are several other east- west street/greenways with better cycle environment and connectivity. The majority of these cyclists would be travelling at a low speed and be aware of the short term parking within the town centre and the potential for dooring Providing a separate bike lane through the retail core has the potential to give cyclists the feel that they have priority which would be in conflict with the parking and pedestrian environment of the retail core. I do not consider the alternative cross section offered by the PTV which includes Copenhagen bike lanes suitable for Main Street. Copenhagen bike lanes are more suited to locations without a high turnover of short term parking with pedestrian activity as in an active retail centre. Furthermore, and most importantly, I consider them to be part of the preferred principal cycle network where there are no other safe options. This is not the case within the ACTC PSP, with bicycle paths within the Boundary Road and Burvilles Road greenway providing this function. 29 October 2013 Cardno 10

11 3.5.2 Vic Roads I consider points 3, 4 and 5 of Vic Roads submission which restrict access to any land fronting onto the Surf Coast Boulevard without a service road to be too restrictive and unnecessary at this stage. There are many examples where corner sites have safe ingress and egress onto a Highway without a service road. The decision of the form of access for corner sites should be provided at the application stage when more information is known about the end land use and the form of access to be provided. This decision should also be balanced against the other urban design, amenity and landscape outcomes sought for Surf Coast Boulevard within the ACTC PSP. Point 6 outlines that Vic Roads has concerns in regards to the Parking Streets intersecting with the service roads. It is difficult to predict to the level of traffic anticipated to use these streets until more detail design of both the land use and the streets are undertaken. However based upon the connectivity of the street network and the access to signals I consider that the volumes anticipated to use the service roads from the parking streets will be modest and self-regulating. If delays tend to occur at the exits from the service road then motorists will reassign their trips onto the multiple other choices to travel south on the Surf Coast Boulevard via Connector Road B, Main Street and Burvilles Road. Point 9 requests that the scope of the works for the four Surf Coast Boulevard intersections needs to be increased to include: > Double right turn lanes on the eastern legs (Double right turns are noted on some concepts, but these should be drawn to ensure that any land implications are included); > Splitter islands on all side road legs; > Reshaping and asphalt surfacing of intersection approaches and turning areas; and > Street lighting of the Surf Coast Highway including intersections, central medians and outer separators. Surf Coast Boulevard intersection costings adopted within the ACTC PSP DCP reflect those agreed for the West PSP DCP. Whilst these associated concept plans included in Appendix C of the DCP report do not include double right turns lanes on the eastern approaches of Main Street, Connector Road B and Boundary Road, the costing undertaken on these approaches allowed for a longer length of the eastern leg of the intersection than would be required for double lanes on these approaches. Therefore there would be little difference between the costing of the two options and would be covered in the contingencies. Additionally, acknowledging the likely need for ultimate double right turns on the eastern approaches of Main Street, Burvilles Road and Boundary Road intersections (as identified in the intersection analysis undertaken and presented within Section 9 of the Armstrong Creek Town Centre Movement and Access Technical Background Report) additional land has been included within road reserves of these approaches within the ACTC land budget. 3.6 Kings Lawyers on behalf of 388 Boundary Road The Johnson s own the property located in the North-East corner of the ACTC. Their submission suggests that the intersection of Boundary Road and Connector Road A is a high priority intersection whose construction should be entirely funded by the DCP. Currently it is proposed that only the signal hardware component of the intersection be funded by the DCP (DI_RO_5 Intersection Boundary and Connector A, $662,106) with the civil works to be funded by the land owner consistent with the treatment of other road works. I agree that the intersection and Connector Road A will be important infrastructure elements providing access into the ACTC and would ideally be constructed early in the development of the centre. However as mentioned earlier Council has not produced a priority plan for the delivery of roads and intersections and their delivery will be negotiated as each application is lodged. 29 October 2013 Cardno 11

12 4 Conclusion Having reviewed relevant submissions that raise traffic and transport matters, it is my view that: > The Armstrong Creek Town Centre Movement and Access Technical Background Report (10th December 2012) prepared by my firm provides a robust and considered assessment of the traffic and transport issues within the Armstrong Creek Town Centre. > Relevant traffic and transport issues raise within submissions can be responded to and adequately addressed with little to no change/impact to the ACTC road and movement networks; and > The proposed road and movement networks within the ACTC PSP as exhibited will appropriately cater for the future traffic and transport needs of the ACTC. 29 October 2013 Cardno 12

13 APPENDIX A QUALIFICATIONS AND EXPERTISE 29 October 2013 Cardno 13

14 Name: Christopher James Butler Address: Cardno 150 Oxford Street Collingwood Vic 3066 Professional Qualifications: > Bachelor of Civil Engineering (Honours), University of Melbourne. Professional Experience: > Cardno Victoria 2007 Present > Grogan Richards Pty Ltd > Road Traffic Authority and RJ Nairn and Partners Pty Ltd Areas of Expertise: > Car parking, traffic and transportation. > Traffic advice and assessment of land uses and development proposals in relation to shopping centre developments, both new and expansions, office developments, local government and government authorities, residential and recreational developments, hospitals, schools, retirement villages and aged care facilities. > Preparation and presentation of evidence before VCAT and Planning Panels Victoria. Expertise to Prepare this Report: My training and experience including involvement with all forms of development over the past 23 years qualifies me to comment on the traffic and car parking implications of the proposal. Instructions which Defined the Scope of this Report: I have been requested by City of Greater Geelong to express my expert opinion as to the car parking implications of the proposal. Facts, Matters and Assumptions Relied Upon: > Armstrong Creek Town Centre Precinct Structure Plan, March 2013, City of Greater Geelong (as exhibited) > Armstrong Creek Town Centre Precinct Structure Plan Design Guidelines, March 2013 City of Greater Geelong (as exhibited) > Armstrong Creek Town Centre Development Contributions Plan, March 2013, City of Greater Geelong (as exhibited) > Armstrong Creek Town Centre Movement and Access Technical Background Report, 10th December 2012, Cardno > Armstrong Creek Town Centre Movement and Access Technical Report Phase 1, 8 th March 2012, Cardno > Relevant submissions as listed in this report 29 October 2013 Cardno 14

15 Identity of Persons Undertaking the Work: Chris Butler, assisted by Aaron Walley, Cardno Victoria. Chris Butler Principal for Cardno 29 October 2013 Cardno 15

16 APPENDIX B CIRRICULUM VITAE 29 October 2013 Cardno 16

17 Chris Butler Current Position Division Manager - Victoria Senior Principal Profession Engineer Years' Experience 26 Years Joined Cardno October 1988 Education Bachelor of Engineering Honours Affiliations VPLEA UDIA AITPM Summary of Experience Chris Butler is the Senior Principal and the Division Manager for Cardno Victoria. His responsibilities include client relationships, quality, financial performance, marketing strategy, human resources, risk and business systems for over 140 staff in Victoria. The Victorian Division capabilities include design, delivery, monitoring and analysis in the following areas: > Transport Planning > Traffic Engineering and Parking > Building Structures > Building Hydraulics & Fire Services > Civil Infrastructure > Water Sensitive Urban Design > Flood & Drainage Services > Survey Chris is a member of the Victoria Planning and Environmental Law Association, UDIA Victoria and AITPM. His qualifications include a Bachelor of Engineering (Hons) from the University of Melbourne. Chris's career commenced over 27 years ago in State Government with Vic Roads (formerly the RTA) working in traffic signal design where he was trained as a SCATS engineer implementing tram priority throughout metropolitan Melbourne. Following on from the RTA, Chris joined a small consulting firm specialising in transport planning and economics on large scale projects and overseas projects. In 1988 Chris joined Grogan Richards and progressed to Director and Shareholder before merging the company with Cardno in Chris's technical expertise lies in the area of project management of large scale transport, traffic and road projects. He has worked with private industry and government clients to deliver practical and economic road and transport outcomes for projects. These projects range from developing, design and costing of transport infrastructure for new precincts for residential growth areas to changing the transport infrastructure in city blocks to accommodate new developments such as Crown Casino. His list of clients include Vic Roads, Department of Transport, Lend Lease, Mirvac, Westfield, Stocklands, CBus and the City of Melbourne to name a few. Chris regularly presents at VCAT and Panel Hearings as an expert witness on behalf of private and government clients. CHRIS BUTLER Page 1 of 3

18 Significant Projects > Flemington Racecourse Master Plan and continuing event management of the Spring Carnival > Crown Casino > Waterfront City Precinct Melbourne Docklands > Ballarat West Structure Plan > Master planning for the Royal Melbourne, Children and Womens Hospitals in Melbourne and several other regional hospitals throughout Victoria. > Master planning studies at Monash University Clayton, La Trobe University Bundoora and Bendigo > Master Planning and design of the road infrastructure, public transport facilities and car parks at Westfield Plenty Valley, Fountain Gate and Geelong shopping centres. > Tram and Bus studies on several of Melbourne's major transport routes > Mirvac's Yarra Waters Precinct, Melbourne Docklands > Melbourne and Olympic Parks > Tooronga Shopping Centre Development > Kingdom of Bhutan, road planning > PNG Road Feasibility Studies > Various traffic signal design and linking projects throughout Melbourne and Canberra CHRIS BUTLER Page 2 of 3

19 Professional History 2008 Current Division Manager - Cardno Vic Chris is the Division Manager for Cardno Victoria. His responsibilities include the management of client relationships, quality of service, financial performance, marketing, strategy, human resources, risk and business systems for over 140 staff Business Unit Manager - Traffic & Transport Chris was the leader of the most respected Traffic & Transport business in Victoria. During his leadership the business unit grew considerably and the range of services offered was successfully diversified Director - Grogan Richards Chris was a Director of Grogan Richards and a member of it's Executive Team. Chris project managed several large scale multi-disciplinary projects including Plenty Valley Shopping Centre for Westfield and Flemington Racecourse for Racing Victoria Associate - Grogan Richards Chris was critical to the success of the Traffic & Transport business and the growth of the firm. Chris managed several large scale retail and transport projects during this period Senior Engineer - Grogan Richards Traffic Engineering responsible for managing several large Traffic & Transport projects, especially for retail developments. Chris was able to bring in new large road planning and design work from Vic Roads Transport Engineer - R.J. Nairn and Partners Transport modelling using SATURN, TRANSTEP and CARTS software programmes for projects in Melbourne, Canberra and overseas projects. Work for the ACT government implementing traffic signal and linking designs in Canberra. Worked on overseas projects in Papua New Guinea for AusAide and the Kingdom of Bhutan for the Asian Development Bank Engineer - Vic Roads (Formerly RTA) Responsible for the design of signalised intersections, design and preparation of traffic signal logic and signal co-ordination. This work was undertaken in metropolitan Melbourne and the regional cities of Ballarat and Bendigo. CHRIS BUTLER Page 3 of 3

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