MARIBYRNONG PLANNING SCHEME AMENDMENT C143 · Level 12, 120 Collins Street, Melbourne. My qualifications and experience is described in Appendix 1. 2. I have been engaged by Intrapac

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14 MARCH 2018 2-4 MEPHAN STREET, MARIBYRNONG PREPARED FOR INTRAPAC PROPERTY

MARIBYRNONG PLANNING SCHEME AMENDMENT C143 STATEMENT OF TOWN PLANNING EVIDENCE

PREPARED BY SARAH HORSFIELD

ON BEHALF OF INTRAPAC PROPERTY

URBIS C143 EVIDENCE

URBIS C143 EVIDENCE FINAL

INTRODUCTION 1

1. INTRODUCTION 1. My name is Sarah Kate Horsfield and I am a Director of Urbis Pty Ltd which conducts its business at

Level 12, 120 Collins Street, Melbourne. My qualifications and experience is described in Appendix 1.

2. I have been engaged by Intrapac Property (Intrapac) to prepare town planning evidence in relation to a proposed Planning Scheme Amendment C143 to the Maribyrnong Planning Scheme, which affects land at 2-4 Mephan Street, Maribyrnong.

3. Amendment C143 proposes the following changes to the Maribyrnong Planning Scheme:

Amend Clause 21.01 (Municipal Strategic Statement), to reference Gordon and Mephan Precinct as a Local Area.

Amend Clause 21.02 (Municipal Profile) to reference Gordon and Mephan Precinct as a Core Employment Area.

Amend Clause 21.03 (Council Vision), to show the Gordon and Mephan Precinct as a Core Employment Area on the ‘Land Use Framework Plan’.

Amend Clause 21.04 (Settlement), to delete reference to Gordon and Mephan Precinct as a Strategic Employment Investigation Area.

Amend Clause 21.05 (Environment and Landscape Values), to show the Gordon and Mephan Precinct as a core Employment Area on the ‘Housing Framework Plan’.

Amend Clause 21.08 (Economic Development), to reference Gordon and Mephan Precinct as a Core Employment Area, and show the Gordon and Mephan Precinct as a Core Employment Area on the ‘Industrial Related Employment Land Framework Plan’.

Amend Clause 21.11 (Local Areas), to include Gordon and Mephan Precinct as a Local Area and provide precinct specific planning policy.

Amend Clause 21.12 (Reference Documents) to incorporate the Gordon and Mephan Precinct Framework Plan (February 2015) as a reference document under the Economic Development” subheading.

4. In the course of preparing this evidence I have inspected the subject site and its environs, and reviewed the documents associated with the proposed Amendment. I have also reviewed the relevant background strategies and framework plans, and relevant Council meeting minutes which have considered the proposed planning scheme amendment.

5. A summary of my opinions with respect to the proposal is as follows:

• The designation of the subject site for Core Employment purposes is not supported by an appropriate strategic basis.

• The Gordon and Mephan Street Precinct Framework Plan did not undertake a sufficiently comprehensive assessment of the area’s strengths and weaknesses, and as a result it presents an incomplete appraisal of the subject site’s physical circumstances, inherent limitations and prospects for employment growth.

• Assessment of the subject site against the performance criteria established through the Maribyrnong Economic and Industrial Development Strategy (MEIDS), confirms that the retention of the subject site for industrial land use is not an appropriate or orderly planning outcome. The assessment concludes that the subject site warrants consideration as a Strategic Redevelopment Site.

• The policy provisions to be introduced to the precinct under Amendment C143 should not be applied to the subject site, on the basis that they are prejudicial to the site’s future as a Strategic Redevelopment Site.

2 INTRODUCTION URBIS

C143 EVIDENCE

• The proposed Amendment should be split into two parts: Part 1 dealing with the existing Amendment insofar as it applies to employment land to the south of Mephan Street, and Part 2 of the Amendment facilitating the exhibition of a rezoning proposal for the subject site, to a Mixed Use Zone with a Development Plan Overlay.

6. I declare that I have made all the enquiries that I believe are desirable and that no matters of significance which I regard as relevant have, to my knowledge, been withheld from the Panel.


SUBJECT SITE AND SURROUNDS 3

2. SUBJECT SITE AND SURROUNDS 7. The subject site is located within the suburb of Maribyrnong and is located approximately 7.6km north

west of the CBD.

8. The land comprises a single parcel (Plan CP167197) with an overall site area of approximately 14,720 square metres. The subject site enjoys a primary frontage of 92m to Mephan Street, and a secondary frontage to Birdwood Street to the north. The east and west side boundaries of the subject site are approximately 160 metres in length. The eastern boundary adjoins a laneway (unnamed) and to the east of the laneway are a number of residential properties which are generally double storey in scale. Most of these residential properties have garages which are accessed from this laneway.

9. The western boundary of the subject site adjoins a street of residential dwellings fronting Allara Avenue, all of which are double storey. The private open space areas associated with these dwellings are located on the eastern side of the dwellings, immediately adjoining the subject site’s western boundary.

10. The land parcel at 2-4 Mephan Street is occupied by a manufacturing business, RMAX, who manufacture insulation and ‘GeoFoam’ products for use in the building and construction industry.

11. The subject site is also occupied by a two storey office which addresses the Mephan Street frontage. To the rear of the office are three large industrial buildings, a storage yard and an area of concrete hard stand. Two large tanks are located in the north eastern corner of the subject site and other smaller out buildings are also present on the site.

12. Vehicle access to the subject site is from the Mephan Street frontage, with two crossovers providing ingress and egress. Vehicles and trucks are directed to access the property from the eastern most crossover and exit from the western crossover. A single crossover is also located at the rear of the subject site however it does not appear to be in active use.

13. RMAX has identified that its manufacturing operations at the subject site will cease by the end of 2018, and that they will vacate the land immediately thereafter. No tenant has been found to occupy the subject site once the current operations cease.

14. The subject site is located in the Industrial 3 Zone and is affected by a Development Contributions Overlay which has been broadly applied to the surrounding land. No other overlays apply to the land.

15. The surrounding area can be described as follows:

• To the north, over Birdwood Street is a residential area which is generally split between two zones. The land to the north west of the subject site is in the General Residential Zone (Schedule 1) and the land to the north east is located in the Neighbourhood Residential Zone. Dwellings are generally single storey in scale and detached.

• To the west, the subject site is adjoined by residential land which is located in the General Residential Zone (Schedule 1). Most of the dwellings to the west are double storey in height and are generally of a more contemporary form and architectural style that those to the north. A childcare centre and kindergarten is located on the corner of Mephan Street and Allara Street.

• To the east in the area south of Birdwood Street land is zoned General Residential (Schedule 1) and is generally characterised by double storey dwellings. Immediately east of the subject site on the north side of Mephan Street are residential properties that are located in the Mixed Use Zone (Maribyrnong Mixed Use Areas). There are no specific objectives, requirements or maximum building heights specified in the schedule to this Mixed Use Zone.

• To the south on the opposite side of Mephan Street, land is located in an Industrial 3 Zone. There are eight small warehouses that are occupied by a variety of businesses including a water tank supplies business, a bakery, and a building and construction company. Further east, warehouses in the employment precinct are generally of a larger scale and appear to be used for clothing manufacturing as well as ‘direct to the public’ clothing outlets. To the east of the Industrial 3 Zone is land located in the Public Use Zone (Schedule 2). This land is occupied by the Footscray Aged Care facility and Footscray North Primary School.

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C143 EVIDENCE FINAL

3. EXISTING PLANNING PROVISIONS 16. The subject site is located in the Industrial 3 Zone. There are no specific conditions stipulated in the

corresponding schedule. The Industrial 3 Zone seeks:

To implement the State Planning Policy Framework and the Local Planning Policy Framework, including the Municipal Strategic Statement and local planning policies.

To provide for industries and associated uses in specific areas where special consideration of the nature and impacts of industrial uses is required or to avoid inter-industry conflict.

To provide a buffer between the Industrial 1 Zone or Industrial 2 Zone and local communities, which allows for industries and associated uses compatible with the nearby community.

To allow limited retail opportunities including convenience shops, small scale supermarkets and associated shops in appropriate locations.

To ensure that uses do not affect the safety and amenity of adjacent, more sensitive land uses.

17. Only one overlay affects the land and this is the Development Contributions Plan Overlay (Schedule 2 – Maribyrnong, North Maidstone and North Footscray Community Infrastructure Development Contributions Plan.

18. The summary of costs specified in the DCP Schedule relates to cost associated with funding ‘community and activity centres’ between 1998 and 2016. A contribution of $450 per net new dwelling was payable and no contributions were payable for non-residential development.

19. The subject site is not affected by any other overlays. An Environmental Audit Overlay is located to the immediate west of the subject site and a precinct Heritage Overlay (HO12) is located to the immediate north.


EXISTING PLANNING PROVISIONS 5

Figure 1 – Zoning Map

6 THE PROPOSED AMENDMENT URBIS

C143 EVIDENCE FINAL

4. THE PROPOSED AMENDMENT 20. At a high level, Amendment C143 seeks to implement:

the recommendations of the Gordon and Mephan Precinct Framework Plan (February 2015) by amending the Municipal Strategic Statement and introducing local planning policy to protect and strengthen the economic role of the precinct, improve amenity and access and support the development of key sites.

21. More specifically, Amendment C143 proposes the following changes to the Maribyrnong Planning Scheme:

Amend Clause 21.01 (Municipal Strategic Statement), to reference Gordon and Mephan Precinct as a Local Area.

Amend Clause 21.02 (Municipal Profile) to reference Gordon and Mephan Precinct as a Core Employment Area.

Amend Clause 21.03 (Council Vision), to show the Gordon and Mephan Precinct as a Core Employment Area on the ‘Land Use Framework Plan’.

Amend Clause 21.04 (Settlement), to delete reference to Gordon and Mephan Precinct as a Strategic Employment Investigation Area.

Amend Clause 21.05 (Environment and Landscape Values), to show the Gordon and Mephan Precinct as a core Employment Area on the ‘Housing Framework Plan’.

Amend Clause 21.08 (Economic Development), to reference Gordon and Mephan Precinct as a Core Employment Area, and show the Gordon and Mephan Precinct as a Core Employment Area on the “Industrial Related Employment Land Framework Plan”.

Amend Clause 21.11 (Local Areas), to include Gordon and Mephan Precinct as a Local Area and provide precinct specific planning policy.

Amend Clause 21.12 (Reference Documents) to incorporate the Gordon and Mephan Precinct Framework Plan (February 2015) as a reference document under the Economic Development” subheading.


STATE PLANNING POLICY FRAMEWORK (SPPF) 7

5. STATE PLANNING POLICY FRAMEWORK (SPPF) 22. Relevant Clauses of the State Planning Policy Framework (SPPF) include the following.

23. Clause 11 ‘Settlement’ recognises that ‘planning is to anticipate and respond to the needs of existing and future communities through provision of zoned and serviced land for housing, employment, recreation and open space, commercial and community facilities and infrastructure.’ Further, this Clause recognises the need for ‘a high standard of urban design and amenity.’

24. Clause 11.02-1 ‘Urban Growth’ seeks to ‘ensure a sufficient supply of land is available for residential, commercial, retail, industrial, recreational, institutional and other community uses.’

25. Clause 11.06-1 ‘Jobs and investment’ seeks to ‘create a city structure that drives productivity, attracts investment and supports innovation and creates jobs’. This will be achieved by:

• Supporting major transport gateways as important locations for employment and economic activity.

• Planning for industrial land in suitable locations to support employment and investment opportunities.

• Ensure there is sufficient industrial land available for development near transport gateways.

• Improve access to jobs across Melbourne and closer to where people live.

• Plan for and facilitate the development of urban-renewal precincts as high amenity mixed use neighbourhoods that offer a range of choice housing and other services.

• Plan for new development and investment opportunities on the existing and planned transport network.

26. Clause 11.06-2 ‘Housing choice’ seeks ‘To provide housing choice close to jobs and services’ by (selected):

• Facilitating increased housing in the established areas to create a city of 20 minute neighbourhoods close to existing services, jobs and public transport.

• Delivering more housing close to jobs and transport.

• Directing new housing and mixed use development to urban renewal precincts and sites.

• Support new housing in activity centres and other places that offer good access to jobs.

27. Clause 15 ‘Built Environment and Heritage’ seeks to ‘ensure that all new land use and development appropriately responds to its landscape, valued built form and cultural context, and protect places and sites with significant heritage, architectural, aesthetic, scientific and cultural value.’ Further this Clause seeks to ensure that planning achieves high quality urban design and architecture that ‘contributes positively to local urban character and sense of place’ whilst minimising detrimental impact on neighbouring properties.

28. Clause 16 ‘Housing’ seeks to:

• Increase the supply of housing in existing urban areas by facilitating increased housing yield in appropriate locations, including under-utilised urban land and

• To locate new housing in or close to activity centres and in urban renewal precincts and sites that offer good access to jobs, services and transport

These strategies are to be achieved by (selected):

• Increase the proportion of new housing in designated locations within established urban areas and reduce the share of new dwellings in greenfield and dispersed development areas.

• Encourage higher density housing development on sites that are well located in relation to jobs, services and public transport.

8 STATE PLANNING POLICY FRAMEWORK (SPPF) URBIS

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• Ensure an adequate supply of redevelopment opportunities within established urban areas to reduce the pressure for fringe development.

• Identify opportunities for increased residential densities to help consolidate urban areas.

29. Clause 17.02-1 ‘Industrial Land Development’ seeks to ‘ensure availability of land for industry’ through the following strategies:

• Identify land for industrial development in urban growth areas where:

Good access for employees, freight and road transport is available.

Appropriate buffer areas can be provided between the proposed industrial land and nearby sensitive land uses.

• Protect and carefully plan existing industrial areas to, where possible, facilitate further industrial development.

• Provide an adequate supply of industrial land in appropriate locations including sufficient stocks of large sites for strategic investment.

• Protect industrial activity in industrial zones from the encroachment of unplanned commercial, residential and other sensitive uses which would adversely affect industry viability.

• Encourage industrial uses that meet appropriate standards of safety and amenity to locate within activity centres.

• Avoid approving non-industrial land uses, which will prejudice the availability of land for future industrial requirements, in identified industrial areas.”

30. Clause 17.02-2 ‘Design of industrial development’ seeks ‘To facilitate the sustainable development and operation of industry and research and development activity’ through the following strategies:

• Ensure that industrial activities requiring substantial threshold distances are located in the core of industrial areas.

• Encourage activities with minimal threshold requirements to locate towards the perimeter of the industrial area.

• Minimise inter-industry conflict and encourage like industries to locate within the same area.

• Provide adequate separation and buffer areas between sensitive uses and offensive or dangerous industries and quarries to ensure that residents are not affected by adverse environmental effects, nuisance or exposure to hazards.

• Encourage manufacturing and storage industries that generate significant volumes of freight to locate close to air, rail and road freight terminals.


LOCAL PLANNING POLICY FRAMEWORK (LPPF) 9

6. LOCAL PLANNING POLICY FRAMEWORK (LPPF) 6.1. MUNICIPAL STRATEGIC STATEMENT (MSS) 31. Clause 21.02 ‘Municipal Profile’ identifies that the City of Maribyrnong is a changing municipality, with

transition occurring in the municipality’s industrial base, as well as growing pressure and demand for residential use. It notes that as a result of these change processes, there are now many redundant and underutilised industrial sites. The profile statement emphasises however that not all industrial land should transition to residential or mixed use. It notes that whilst there has been a decline in the number of traditional ‘production style’ jobs, there has also been an increase in the proportion of ‘service sector’ jobs.

32. Clause 21.03 ‘Council Vision’ identifies the overarching vision of Council to be:

A diverse, vibrant, and proud city focused on people-based places, environmentally sustainable practices, and opportunities to enhance community health and wellbeing through education, responsive services and participation in community life.

33. The land use vision for the municipality notes:

A broad economic base will strengthen local employment through a strong retail sector, new offices and business services, a growing arts base and the renewal of the city’s industrial areas.

34. Clause 21.04 ‘Settlement’ identifies the Gordon and Mephan Street precinct as a ‘Strategic Employment Investigation Area’ at Clause 21.04-5. It goes on to say:

The area is located east of Gordon Street and predominantly south of Mephan Street, but also includes one large parcel north of Mephan Street, between Mephan and Birdwood Streets. The close proximity of new residential development to existing industrial uses potentially gives rise to amenity issues at the interface, including heavy vehicle usage of partially residential streets, industry noise and visual impact.

35. Clause 21.07 ‘Housing’ provides a housing growth area framework which categorises residential land into a hierarchy of areas based on the degree to which they are anticipated to change, evolve and become more densified. The majority of land surrounding the subject site is included in an ‘Incremental change area’ which is defined as:

All other residential areas without heritage significance or an identified residential character that warrants planning protection through specific overlays

36. Clause 21.08 ‘Economic Development’ specifically details ‘Industrial Related Employment Land’ at Clause 21.08-3. The subject site is located in ‘Precinct 9 – Gordon and Mephan Street’. This precinct is considered to be a ‘Strategic Employment Investigation Area’ (SEIA) which is defined as follows:

Areas which are considered to be suitable for employment until such time as further investigation clearly demonstrates that this is not a viable option.

SEIAs are identified from the stock of Industrial Related Employment Land (IREL) determined to require investigation through a framework/structure planning process, because there are significant limitations or issues relating to their continued employment role.

Areas in which these limitations are able to be addressed and the employment role retained or increased, are likely to be designated CEA.

Areas determined to be inherently/intrinsically unsuitable for an employment role, are likely to be designated SRS.

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6.2. LOCAL PLANNING POLICES 37. There are no local planning policies of relevance to the proposal.

6.3. RELEVANT REFERENCE DOCUMENTS 38. The following reference documents are of relevant to the proposal.

6.3.1. Maribyrnong Economic and Industrial Development Strategy (October 2012)

39. The Maribyrnong Economic and Industrial Development Strategy (MEIDS) was prepared by AEC Group, in association with Jones Lang LaSalle Research and Tract Consultants. The MEIDS work was jointly funded by the Victoria Government (Department of Planning & Community Development) and the City of Maribyrnong.

40. MEIDS is split into two parts. Part 1 is the ‘Economic Development Strategy’ and Part 2 is the ‘Industrial Land Strategy’. The overarching objectives of MEIDS are:

• Recommend strategies that assist to ensure the City's long term economic health;

• Assist local business, industry and Council in making investment decisions;

• Ensure opportunities for local employment are identified and acted upon;

• Ensure enough land is available for economic development in the context of pressures for residential development;

• Promote continued economic development in the City of Maribyrnong;

• Identify a strategic land use framework for industrial land that is complementary to existing regional and state level industrial land use policies and strategies;

• Identify core industrial land that must be retained for current and future use including land for alternative uses e.g., residential;

• Determine the future strategic direction for industrial and semi-industrial/commercial land throughout City of Maribyrnong; and

• Provide guidance on sensitive land use surrounding industrial and semi industrial/commercial land, and land for major redevelopment opportunities.

41. The key issues that Part 1 of MEIDS investigates are:

• Managing Population Growth (Section 2.1)

• Concentrations of Low Socio-Demographic and High Disadvantage (Section 2.2)

• Gentrification of Selected Areas (Section 2.3)

• Declines in Industrial & Manufacturing Activity (Section 2.4)

• Growth of the Port of Melbourne (Section 2.5)

• Industrial Property Trends (Section 2.6)

• Conflicting Land Use Issues (Section 2.7)

• Ensuring Economic Sustainability (Section 2.8)

42. Part 2 (Industrial Land Strategy) of the MEDI Strategy has the following objectives:

• Provide a precinct based approach to industrial land within Maribyrnong;

• Provide an economic analysis of each industrial precinct and determine its economic future;

• Identify core industrial land that must be retained for current and future use;


LOCAL PLANNING POLICY FRAMEWORK (LPPF) 11

• Identify underutilised industrial land that exceeds forecast business needs and can be developed and/or redeveloped for commercial and other land uses such as residential;

• Detail the elements and studies required for physical framework plans;

• Develop an action plan for each industrial precinct;

• Provide an implementation plan for actions that identify resources required, potential partners and timelines; and

• Develop a monitoring program for the implementation of the strategy.

43. MEIDS determined that different terminology was necessary to define certain areas beyond just the classification of “Industry”. The terminology is outlined on Page 4 as follows:

a. Industry Related Employment Area (IREA)

b. Core Employment Area (CEA)

c. Strategic Employment Investigation Area (SEIA)

d. Employment Intensification Areas (EIA)

e. Strategic Redevelopment Areas (SRA)

44. Figure 1.3 of MEIDS identifies the Gordon and Mephan Street & Rosamond Road area as ‘Precinct 9’ and more specifically as a Strategic Employment Investigation Area (SEIA). Section 2.1.4 of MEIDS outlines SEIA in more detail. It is noted:

SEIAs need to be examined in a greater level of detail (i.e. subprecinct) to determine if their limitations can be addressed in order for them to retain or intensify their employment role or, if these areas are more suited to mixed use or an alternative role e.g. entirely residential. Those identified as the former are categorised as an Employment Intensification Area (EIA) and the latter as a Strategic Redevelopment Area (SRA).

Additional considerations can also be taken into account including:

▪ The degree of residential interface;

▪ The status of the local road network;

▪ Proximity to schools and other community facilities;

▪ Ability of existing uses in the precinct to maintain their operations if they desire; and

▪ Strategic land use context e.g. the land:

is on a major road which is strategically suited to providing a very high amenity impression of the municipality;

is at a key gateway which requires high amenity; or

is in proximity to an activity centre.

45. Performance criteria is applied to sub-precincts within the SEIA. Sub-precincts that achieve over 60% are categorised as Employment Intensification Areas and those that do not as Strategic Redevelopment Areas. Precinct 9 is split into two sub-precincts. Precinct 1 was a standalone site known as the Pelaco site. The balance of the Precinct is considered to be sub-precinct 2 and this is where the subject site is located.

6.3.2. Gordon and Mephan Street Precinct Framework Plan (GMPFP)

46. The Gordon and Mephan Street Precinct Framework Plan (Feb 2015) was prepared by SGS Economics and was endorsed at a full Council meeting shortly after its publication.

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47. The GMPFP recognises that at Part 2 of MEIDS, the Gordon and Mephan Street Precinct was designated as a Strategic Employment Investigation Area and states:

Of particular significance is the policy guideline that if this precinct (as an SEIA) is not found to possess significant limitations or issues which cannot be addressed in order for it to retain or increase its employment role it should continue to play an employment role.

48. At Section 2.5 (Economic Trends) it is noted that there are variations in the composition of local economies when compared with Brimbank, Hobsons Bay, Melton and Wyndham where manufacturing and transport/logistics largely underpin the employment base in these municipalities. In the case of Maribyrnong and Moonee Valley, there is a slightly different profile with a greater proportion of ‘high value added services, for example, telecommunications, medical services, engineers and other consults, software engineers, lawyers, accountants and so on.’

It is noted at Section 3.1 (Employment) that the total employment numbers in Maribyrnong remained unchanged between 1996 and 2011 however the employment numbers in the precinct rose from 199 in 1996 to 418 in 2011. It also states:

No industry has recorded a decline in economic activity. Manufacturing employment in the precinct recorded a slight increase. The presence of 65 manufacturing jobs recorded in the 2011 ABS Census were largely confirmed through the consultation process which is discussed in further detail in Section 4.

49. With respect to ‘interface issues’ the GMPFP states:

Although the precinct is adjacent to residential development, the current land uses and built form appear to present no obvious issues with regard to land use conflicts at the interfaces of the industrial and residential zoned land. The typical interface treatments are relatively modest scale, blank walls, setback from property boundaries and, as such – with the exception of aesthetic considerations – these configurations do not present any issues to the residential development and school immediately adjacent the precinct

50. At Section 3.9 (Planning Strategy for the Gordon and Mephan Precinct), the main reasons for the decision to protect and enhance the precinct’s employment roles were:

Significant employment numbers which appeared to only be increasing despite difficult macroeconomic conditions.

A number of promising start‐up businesses had established in the precinct. The owners of the businesses had expressed the desire to remain in the precinct and expand their operations over time.

The fact that Maribyrnong is not presently under pressure to find additional housing capacity as strategic work identifies the long term supply of housing sites within Activity Areas and key sites as listed in Clause 21.07 of Council’s MSS.

The precinct is currently under serviced by community infrastructure and so is not considered a priority area for new housing.

51. With respect to housing needs, it is noted that the precinct is close to Footscray, shopping areas including Highpoint, schools and services and therefore might be considered for potential residential development and that the conversion of industrial uses to residential uses has been a trend in the immediate area.

52. The conclusion reached by the GMPFP was that the employment uses in the Gordon and Mephan Street precinct should be retained and elevated to a core employment area.

53. Section 4 goes on to detail the Framework Plan including key directions, vision, and objectives relating to: use and economic development objectives, movement and accessibility, character and identity. Section 4.7 (Specific guidance for key site) identifies the subject site, amongst three others, with specific guidelines and strategies for their future evolution.


ASSESSMENT 13

7. ASSESSMENT 54. I believe the key issues for assessment in this matter are as follows:

• The extent to which the Amendment is supported by an appropriate strategic basis;

• The consistency of the proposed Amendment with the State and Local Planning Policy Frameworks;

• The strategic land use role of the subject site;

• Recommended changes to the proposed planning regime for the subject site.

55. I will address each of these matters in the following sections of my report.

7.1 STRATEGIC BASIS FOR THE PROPOSED AMENDMENT 56. It is evident that the Amendment has its strategic foundations in the work carried out in 2012 by AEC

as part of MEIDS, which critically examined the industrial role and future of the municipality’s employment precincts.

57. One of the primary outcomes of this work was the designation of industrial land across the municipality as either a Core Employment Area or Strategic Employment Investigation Area. These designations flowed from an assessment of each precinct against a series of key performance criteria focused around the physical circumstances of the precinct, its contribution to local employment, its accessibility and strategic land use context, and a range of other macro level considerations.

58. A precinct was designated as a Core Employment Area in circumstances where the precinct complied with a clear majority of the performance criteria (over 60%). The SEIA designation was applied to precincts with a score under 60%, that warranted further analysis to determine if their limitations could be addressed or overcome in a manner that would allow these sub-precincts to retain or intensify their employment role into the future.

59. The Gordon and Mephan Street precinct was identified as a ‘Strategic Employment Investigation Area,’ on the basis that it achieved a score of only 50% against the performance framework. The SEIA concept is described in MEIDS as follows:

Areas which have more significant limitations or issues which require investigation to determine with they can be addressed in order for them to retain or increase their employment role. If these limitations cannot be addressed, these areas are determined to be inherently/intrinsically unsuitable for an employment role. SEIA’s are considered to be employment areas until such time as further investigation clearly demonstrates that this is not a viable option. (p.10 MEIDS Part 2).

60. The Gordon and Mephan Street Precinct Framework Plan (GMPFP) was prepared in 2015 by SGS Consultants, and flowed directly from the MEIDS work, which recommended that a Framework Plan be prepared following further investigations to determine whether the limitations and constraints of the precinct could be overcome.

61. The methodology used by the consultants to advance these investigations is described at p.1 of the GMPFP, and included:

• Examination of local and regional policy frameworks;

• Analysis of local and regional employment data to determine how employment patterns in different industries and geographies have changed over time, and what impact this might have on the precinct;

• Survey of businesses and landowners in the industrial precinct to ascertain their future investment plans;

• Workshop with Council staff.

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62. Crucially, this scope did not include any serious investigation of the land use/amenity conflicts that gave rise to the SEIA designation in the first place.

63. In my opinion, this is a fundamental flaw of the GMPFP.

64. MEIDS specifically called for a more forensic examination of the precinct’s strengths and limitations to determine whether an employment future was appropriate. The Framework Plan offers virtually no assessment of the precinct’s inherent constraints, making only superficial comments around the potential for amenity conflict with surrounding residential uses. Indeed, the only reference to the limitations arising from the co-location of industrial/residential uses in the entire GMPFP document is on p.18, as follows:

Although the precinct is adjacent to residential development, the current land uses and built form appear to present no obvious issues with regard to land use conflicts at the interfaces of the industrial and residential land. The typical interfaces are relatively modest scale, blank walls, setback from property boundaries and, as such – with the exception of aesthetic consideration – these configurations do not present any issues to the residential development and school immediately adjacent the precinct.

65. Aside from this observation, the GMPFP is otherwise silent on issues of amenity conflict, interface issues, noise and traffic impacts, clause 52.10 buffer considerations, and issues associated with the operating characteristics of some existing industries in the precinct that operate on a 24/7 basis (including the subject site). In my opinion, these omissions represent quite fundamental flaws, and undermine the conclusions reached by the document that the whole of the precinct should be elevated as a ‘Core Employment Area.’

66. I say this for the following reasons:

• The GMPFP made assumptions regarding the long term sustainability of industrial uses in this precinct, largely on the basis of feedback from existing businesses that they had an intention to remain.

• No genuine examination of amenity impacts arising from existing uses in the precinct on surrounding residents was made. As a minimum, I would have expected there to be investigation of noise impacts (particularly given the subject site, and potentially other uses in the precinct, operate on a 24 hour basis), as well as traffic impacts from truck and loading activity, potential odour issues and visual amenity impacts at the transition between industrial and residential uses.

• No consultation appears to have been carried out with residents surrounding the precinct, which would have provided important feedback on the extent to which resident amenity is seriously impaired as a result of neighbouring industrial operations.

• The GMPFP fails to recognise that the precinct is not homogenous in its urban form or interface conditions. No differentiation has been made between the single isolated industrial parcel to the north of Mephan Street, and the cluster of industrial sites on the south side of Mephan Street. The approach of treating these sites as a single homogenous entity is in my view overly simplistic.

• The GMPFP has not undertaken a sufficiently comprehensive assessment of the area’s strengths and weaknesses, and as a result it presents an incomplete appraisal of the precinct’s status and prospects for employment growth. It does not confirm whether all parts of the employment precinct are functioning efficiently, or what nature of conflict is being experienced between the precinct and its neighbours. In this regard, I believe the Framework Plan fails to advance the work that was carried out for the precinct by MEIDS over 7 years ago.

67. On the basis of these shortcomings, I do not believe an appropriate case has been made for the subject site to be designated for Core Employment purposes.

68. The GMSFP was clearly intended to build on the level of analysis undertaken by MEIDS so as to resolve a clear future for the SEIA precincts. I do not believe it has achieved this in relation to the subject site, or established an appropriate strategic basis for the policy changes proposed by Amendment C143 for the subject site.


ASSESSMENT 15

7.1. THE CONSISTENCY OF THE PROPOSED AMENDMENT WITH THE STATE AND LOCAL PLANNING POLICY FRAMEWORKS.

Plan Melbourne

69. At a high level, Plan Melbourne recognises that Melbourne will need to provide a further 1.5 million jobs over the next 35 years in a range of ‘priority sectors,’ in particular those that generate high value, knowledge intensive jobs. A series of National employment and innovation clusters (NEICs) have been identified across the metropolitan area as a focus for these new generation industries and employment typologies, recognising the importance of clustering major employment and education activities to drive innovation.

70. Policy 1.1.6 seeks to ‘plan for industrial land in the right locations to support employment and other investment opportunities,’ recognising that outer suburban land is expected to do much of the heavy lifting:

Ensuring there is enough industrial land available for development near transport gateways – particularly in outer-suburban areas – will be critical if Melbourne is to remain globally competitive and attract new investment and jobs.

71. While recognising the importance of protecting those industrial precincts that are recognised as having state significance, Plan Melbourne also acknowledges the potential for renewal and transformation of industrial and brownfield sites that no longer fulfil their function. In particular Director 1.3 states:

‘Identifying and creating opportunities for development on urban renewal sites and precincts across Melbourne can ease pressure on established areas and provide greater certainty for residents, investors, and the construction and development industry.

Some opportunities will come from investment in major transport infrastructure, such as the Metro Tunnel, level crossing removals, and associated land development. Other opportunities will come from brownfield sites, former industrial areas or underutilised or surplus government land.

Renewal of these sites offers the opportunity to improve local amenity, accommodate more housing and offer a greater mix of uses to support local communities.’

72. In my opinion, the constraints of the subject site lend support for its further consideration as an urban renewal opportunity. Consistent with the outcomes desired by Plan Melbourne above, I believe the future renewal of the subject site for residential/mixed use purposes could deliver significant improvements to local amenity while also contributing to housing supply.

State Planning Policy Framework

73. Clause 11.06-1 ‘Jobs and investment’ seeks to ‘create a city structure that drives productivity, attracts investment and supports innovation and creates jobs’. Although the continued utilisation of this land for industrial purposes will in theory provide an opportunity to support employment, the reality of this subject site is that the tenant is exiting and there are many constraints that would deter any new businesses locating at this site.

74. The continued use of the land for industrial related activities also poses some conflict with the objectives of Clause 15 ‘Built Environment and Heritage’ which seeks to ensure that planning achieves high quality urban design and architecture that ‘contributes positively to local urban character and sense of place’ whilst minimising detrimental impact on neighbouring properties.

75. Likewise, there is the potential for conflict between the continued use of the land for industrial purposes and the objectives of Clause 17.02-2 ‘Design of industrial development’ which seeks ‘to facilitate the sustainable development and operation of industry and research and development activity’ through the following strategies:

• Ensure that industrial activities requiring substantial threshold distances are located in the core of industrial areas.

16 ASSESSMENT URBIS

C143 EVIDENCE FINAL

• Encourage activities with minimal threshold requirements to locate towards the perimeter of the industrial area.

• Minimise inter-industry conflict and encourage like industries to locate within the same area.

• Provide adequate separation and buffer areas between sensitive uses and offensive or dangerous industries and quarries to ensure that residents are not affected by adverse environmental effects, nuisance or exposure to hazards.

• Encourage manufacturing and storage industries that generate significant volumes of freight to locate close to air, rail and road freight terminals.

Municipal Strategic Statement (MSS)

76. The predicament of the subject site resonates with Clause 21.02 ‘Municipal Profile’ which states that many of the municipality’s older industries that used to support the local economy have either closed or have left the municipality, primarily as a result of broader structural changes in the economy. Clause 21.02 recognises that there are now many redundant and underutilised industrial sites.

77. Clause 21.04 ‘Settlement’ identifies the Gordon and Mephan Street precinct as a ‘Strategic Employment Investigation Area’ at Clause 21.04-5. It goes on to say:

The area is located east of Gordon Street and predominantly south of Mephan Street, but also includes one large parcel north of Mephan Street, between Mephan and Birdwood Streets. The close proximity of new residential development to existing industrial uses potentially gives rise to amenity issues at the interface, including heavy vehicle usage of partially residential streets, industry noise and visual impact.

78. In my opinion, the potential issues flagged within Clause 21.04 are significant and it is difficult to reconcile how these issues could have been overlooked as they appear to have been in the GMPFP.

7.2. THE STRATEGIC LAND USE ROLE OF THE SITE 79. The strategic role of the subject site requires careful consideration against a range of factors,

including:

• the physical context of the land and its relationship to sensitive uses;

• the extent to which the land is suitable for contemporary industry and employment uses that are permitted under the current Industrial 3 Zone;

• the performance criteria set out in MEIDS that has been used to evaluate the strategic role and land use future of industrial land in the municipality.

80. My observations on these matters are set out below.

Physical Context

81. As noted earlier, the subject site forms an isolated industrial use in an otherwise residential landscape north of Mephan Street. The boundary condition around the subject site is typified by high fencing, blank industrial scale walls, loading and truck access areas, and generally sparse landscaping (except along the site frontage). The bulk and scale of the industrial buildings on the land present a visually dominating element in the skyline when viewed from the surrounding residential streets (refer to Photographs 3 to 8 in Appendix 3).

82. It is evident on inspection of the land that the subject site is significantly more constrained than the industrial properties south of Mephan Street, as a direct result of its proximity to and encroachment by residential uses.

83. To the west the subject site immediately abuts the rear yards of a long row of dwellings which front Allara Avenue. The main egress from the subject site is positioned directly adjacent to this shared boundary. In order to mitigate amenity impacts from the subject site, a large timber wall of approximately 4 metres in scale has been erected (see photographs 1 and 11 at Appendix 3). Although this wall may offer some level of benefit to residents in reducing noise impacts from the subject site, the sheer scale of the wall means that it has a significant shadow impact affecting the rear yards of these dwellings in the morning. I note the scale of this wall is similar to having a double


ASSESSMENT 17

storey dwelling constructed on the shared boundary, with no upper level setback (as would otherwise be required by ResCode).

84. To the east, there is a narrow accessway between most of the adjoining residential properties and the subject site. Given that the subject’s site’s primary access and loading area is located directly adjacent to this boundary, and recognising that the plant operates on a 24 hour basis, I would expect it is highly likely that noise impacts would be experienced by residents along this boundary as a result of the subject site’s operations.

85. To the north, the subject site turns it back on residential precincts north of Birdwood Street, presenting a corrugated/chain wire fence for the length of the boundary. Industrial buildings on the subject site located adjacent to this interface present as quite visually dominating elements in the streetscape.

Land Use Options

86. In practice, I believe the conditions described above present quite serious constraints over the use of the subject site for a large number of uses contemplated by the Industrial 3 Zone.

87. For example, the subject site is unable to accommodate any form of industrial use listed in Clause 52.10 that requires a buffer to residential land (given the subject site is only 72m wide and cannot realistically accommodate any of the threshold buffers set out in this clause).

88. The subject site is not in a suitable strategic location to accommodate any substantial retail or office uses, and in any event policy seeks to direct such uses to locate in activity centres.

89. The subject site could readily accommodate a warehouse use, however the condition stipulated in the zone requires that for a warehouse to be as of right, it must be at least 30m from land in a residential zone. This clearly cannot be achieved on the subject property, which has zero setback from land in residential zones on 3 of its 4 sides. Likewise, even if a permit were to be sought for warehouse use, it would be prevented from storing any of the products listed at Clause 52.10 given the required buffer thresholds could not be achieved (refer to Appendix 2 for list of products/processes that would be prohibited given the subject site’s inability to meet EPA buffer thresholds).

90. In reality, there are only a very limited number of land uses that can be established on the land under the Industrial 3 Zone, and even less that are capable of furthering the employment intensification objectives that Council has enshrined for its core employment precincts. At Appendix 3 I have included an analysis of land uses that are permissible in the Industrial 3 Zone, noting which of these would not be suitable to establish on the subject site in light of the adjacency of residential land. The list of uses that are precluded from establishing is extensive.

91. It is evident that warehousing (specifically warehousing of low risk / low amenity impact goods only) would be the most likely use for the land should the zone remain unchanged. I note that the nature of warehousing is that it is typically a low employment generator in terms of employees per sqm. One must ask the question that if the range of uses possible on the subject site is so limited, the potential for amenity impacts so high, and the potential employment outcomes so low, then is this zone the most appropriate and efficient use of the land?

Assessment against MEIDS Performance Criteria

92. In examining the strategic role of the subject site, I have also given careful regard to the performance criteria ‘tests’ set out in MEIDS, which were used in the strategy to determine whether a site warranted designation as an ‘Employment Intensification area’ or ‘Strategic Redevelopment site.’

93. EIA designations were applied where it was felt that the limitations of the precinct could be readily overcome and a long term industrial use confirmed, while the SRS designation was applied where the limitations of the precinct were considered too great and the site warranted redevelopment for an alternative use (eg residential/mixed use). Those sites scoring less than 50% against the performance criteria were deemed to be candidates for strategic redevelopment.

94. Precinct 9.1 of the Gordon/Mephan Street precinct (also known as the Pelaco site) was one of the sites subjected to further assessment at p. 18 of MEIDS, and was deemed to possess limitations that were intractable in terms of the site’s continued use for employment purposes. The land was therefore identified as a Strategic Redevelopment Site and was subsequently rezoned and developed for residential purposes.

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C143 EVIDENCE FINAL

95. In my opinion, the subject site should have been subjected to a thorough examination against the performance criteria in MEIDS as part of the Framework Plan process, in precisely the same way that the Pelaco site was assessed as a discrete precinct.

96. Like the Pelaco site, the subject site forms an island industrial site, and possesses very similar contextual conditions with direct abuttals to residential land on three sides.

97. As I have stated earlier, I believe the GMPFP applied an overly simplistic approach to the assessment of the precinct, failing to differentiate between the land on the north and south sides of Mephan Street.

98. On the basis that the subject site forms a legitimate sub-precinct in its own right, I have undertaken an assessment of the subject site against the performance criteria set out in MEIDS. My conclusions are as follows:

Criterion Description 2-4 Mephan Street (Subject Site) response Meets Criteria

1. Use / Purpose

Current use is predominantly employment based, including industrial and/or commercial

Current role - manufacturing goods utilised in the construction industry, and ancillary office. The tenant, RMAX has indicated their operations will cease in 2018. No alternative tenant has been found. Location of the subject site, coupled with its extensive residential interface and truck access limitations severely constrains future use options

✓

2. Transition Buffer Role

Currently forms a transition buffer between heavier industrial and sensitive uses or high amenity areas.

Does not comply – the subject site provides no buffer to sensitive uses, being wedged in between residential land to the north, east and west.

3. Statutory Buffer

Land is located within a statutory, legislated or recommended buffer of a nearby use.

No statutory buffer

4. Co-Location Within an area of similar, related or dependent industrial/commercial activities.

Does not comply – the subject site is geographically isolated from the other Industrial 3 Zone land to the south and there are no known synergies that exist between RMAX’s operations and other businesses in the immediate area. The industrial use of the subject site is anomalous in the context of the neighbouring residential areas that surround the subject site.

5. Capital Investment

There is significant sunk capital in the precinct, or recent levels of reinvestment.

No recent investment in the subject site has been made and RMAX has now determined to cease operations. It is acknowledged however that the subject site contains substantial built infrastructure.

✓

6. Employment Precinct has a significant number of employees.

The RMAX operation currently employs 21 people. These jobs will be lost from the precinct by December 2018 when RMAX ceases operations. Until such time as an alternative tenant can be found the subject site will generate zero employment.

7. Access Existing or planned direct (i.e. not through residential areas) access to key transport networks.

Does not comply – truck access to the subject site is a constrained with a local law that restricts truck movements on Mephan Street and through residential areas. This limitation presents a significant barrier for industrial/warehouse operations that generate a high volume of truck movements and rely upon ease of accessibility to the arterial road/freight network.

8. Legislative / Policy Framework

The precinct is recognised for its economic and/or employment role in the planning scheme or other policy/legislative /strategic frameworks.

As it currently stands, the precinct is recognised as a Strategic Employment Investigation Area for further assessment. On this basis, I could not say that the precinct has overwhelming support to function as employment land, only that Council have identified it as needing more strategic work.

Partially

9. Strategic Land Use Context

Nearby uses would benefit from employment use

Partially. Land uses to the north, east and west would benefit from the removal of the employment use, while existing employment uses to the south may benefit from

Partially


ASSESSMENT 19

Criterion Description 2-4 Mephan Street (Subject Site) response Meets Criteria

the critical mass brought by the site’s retention for employment purposes.

10. Existing Uses – Ability to Transition

Presence of operating industries will be affected by sensitive use

Existing industries in the broader area will not be materially impacted by the subject site’s transition to a residential use, on the basis that residential land already occupies all land on the north side of Mephan Street.

Score 3/10

% 30%

Category SRS

99. My assessment produces a score of 30% for the subject site, which obviously falls well short of the 50% benchmark. On the basis of this assessment and my observations regarding the physical context and land use options for the land, it is my firm opinion that the subject site should be confirmed as a ‘Strategic Redevelopment Area,’ suitable for mixed use/residential redevelopment.

7.3. RECOMMENDED CHANGES TO THE PROPOSED PLANNING REGIME FOR THE SITE

100. Accepting that the physical circumstances and constraints of the subject site do not support the use of the land for core employment purposes, it follows that the policy provisions sought to be introduced by the Amendment should not apply to the land. Rather they should be confined to the industrial precinct south of Mephan Street only.

101. In my opinion the subject site clearly warrants separate consideration to the balance of the precinct, on the basis of its more isolated context and pervasive encroachment by residential uses.

102. It is my recommendation that a site specific planning control regime be applied to the land to enable its renewal and redevelopment for mixed use purposes. Rather than deferring the introduction of a new planning framework for the land to a future amendment process, I believe the Amendment could be readily split into two parts, with a new ‘Part 2’ of the amendment proposing the application of a Mixed Use Zone and Development Plan Overlay to the land.

103. The Part 2 Amendment would naturally require public exhibition and re-assessment by this Panel in the event there are submissions that cannot be resolved.

104. In support of this approach I make the following comments:

• The application of a Mixed Use Zone would bring all of the land on the north side of Mephan Street into strategic alignment, providing a logical extension of the existing Mixed Use Zone located immediately east of the subject site across the subject site.

• The DPO tool has been used on other sites that in Maribyrnong to enable their transition and redevelopment from industrial to residential use (eg within the Maidstone Hampstead Road precinct).

• The Mixed Use Zone and DPO requirements will ensure an employment role for part of the subject site is retained into the future, albeit at a much smaller scale.

• The zoning proposal will see long standing amenity conflicts between the subject site and surrounding neighbourhoods removed once and for all, and in turn will enable significant improvements to neighbourhood permeability and the public realm quality of the residential area to be realised.

105. I have prepared a draft DPO control for the land at Appendix 4 for the Panel’s consideration. I consider that the DPO and Mixed Use Zone could form the basis of the Part 2 Amendment proposal, which would need to be placed on public exhibition and examined by the community and businesses in the employment precinct before it is considered further.

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C143 EVIDENCE FINAL

106. Importantly, the draft DPO includes a number of requirements that seek to give effect to the broad objectives of the proposed Clause 21.11-9 regarding improved precinct amenity, pedestrian connectivity, respectful interface conditions and the removal of blank, inactive facades.

107. Key objectives/requirements include:

• To facilitate the integrated development of the land for residential and mixed use employment purposes.

• To support improvements to neighbourhood permeability through the provision of a through site link for pedestrian and cycle access between Mephan and Birdwood Streets.

• The provision of an activated frontage to Mephan Street, so as to retain a localised, small scale employment role for the site.

• To provide appropriate transitions to surrounding properties through the graduation of built form.

• To establish a high quality residential and landscape interface to Birdwood Street that enhances the existing streetscape character.


CONCLUSIONS 21

8. CONCLUSIONS 108. In summary, my conclusions are as follows:

• The designation of the subject site for Core Employment purposes is not supported by an appropriate strategic basis.

• The Gordon and Mephan Street Precinct Framework Plan did not undertake a sufficiently comprehensive assessment of the area’s strengths and weaknesses, and as a result it presents an incomplete appraisal of the subject site’s physical circumstances, inherent limitations and prospects for employment growth.

• Assessment of the subject site against the performance criteria established through the Maribyrnong Economic and Industrial Development Strategy (MEIDS), confirms that the retention of the subject site for industrial land use is not an appropriate or orderly planning outcome. The assessment concludes that the subject site warrants consideration as a Strategic Redevelopment Site.

• The policy provisions to be introduced to the precinct under Amendment C143 should not be applied to the subject site, on the basis that they are prejudicial to the subject site’s future as a Strategic Redevelopment Site.

• The proposed Amendment should be split into two parts: Part 1 dealing with the existing Amendment insofar as it applies to employment land to the south of Mephan Street, and Part 2 of the Amendment facilitating the exhibition of a rezoning proposal for the subject site, to a Mixed Use Zone with a Development Plan Overlay.

Sarah Horsfield Director

APPENDICES


APPENDIX 1 - STATEMENT OF QUALIFICATIONS


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STATEMENT OF QUALIFICATIONS AND EXPERIENCE

NAME AND ADDRESS Sarah Horsfield Director Urbis Pty Ltd Level 12, 120 Collins Street MELBOURNE VIC 3000

Qualifications • Bachelor of Applied Science (Planning) 1995

• Masters of Business Administration (Melbourne Business School) 2006

Professional Experience • Current Position: Director, Urbis Pty Ltd

• 2002 – 2018: Senior Planner, Associate Director and Director Urbis Pty Ltd

• 2000 – 2002: Manager Strategic Planning, City of Kingston

• 1998 – 2000: Town Planner, Tract Consultants

• 1995 – 1998: Town Planner, City of Kingston

Area of Expertise I advise on the development of cities, their principal activities and land uses and have extensive experience in strategic and development planning. I have particular project experience involving major urban development projects across a range of localities and activities including:

• Large residential development in Melbourne’s growth areas;

• Policy advice and strategic planning to government;

• Major retail and mixed use developments;

Expertise to Prepare this Report Professional qualifications and expertise in town planning both in the public and private sectors.

Instructions which defined the Scope of the Report My instructions required me to undertake a town planning assessment and review the merits of the proposal. In so doing, I have relied upon those matters set down below.


APPENDICES

Facts, Matters and Assumptions Relied Upon I have relied upon the following in the preparation of this report:

• Inspection of the subject site and surrounds.

• Review of the Maribyrnong Planning Scheme and strategic background documents.

• Review of the proposed Amendment and supporting documents.

Documents taken into Account Relevant documents are described above.

Identity of Persons undertaking the work Sarah Horsfield assisted by Andrew Lanarus, Associate Director

Summary of Opinions A summary of my opinions in relation to this matter is included at paragraph no. 5 of my evidence.

Sarah Horsfield Urbis Pty Ltd

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APPENDIX 2 - ASSESSMENT OF LAND USES IN INDUSTRIAL 3 ZONE


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109. The following table sets out the land uses that are permissible on the subject site. I provide some commentary on the likelihood of each use being established on the subject site:

Land Use Probability of Being Established

Comment

Section 1 ‘Permit not required uses’:

Convenience Shop Low A convenience store could only form a small part of the future development of the subject site.

Crop Raising Low Crop raising would not be the highest and best use of the land in an urban setting

Extensive animal husbandry Low Extensive animal husbandry would not be the highest and best use of the land in an urban setting

Home based business Low Other than a caretaker’s house, all other ‘accommodation’ uses such as dwellings are prohibited

Informal outdoor recreation Low Defined by uses such as cycle track, picnic or barbecue area, playground, and walking or jogging track – this would not be a profitable use of the land for the land owner.

Mail centre Low A very niche use with a low probability of being established on the subject site

Railway Low There are no known railways to be directed through the subject site.

Service Station (subject to conditions)

Low - moderate A very low prospect on its own, although could be established as part of a larger development.

Shop (other adult sex product shop, convenience shop, restricted retail premises and supermarket (subject to conditions

Moderate A large shop or cluster of shops would likely be better suited to routes with increased traffic flow such as Gordon’s Road.

Supermarket (subject to conditions)

Moderate The supermarket could not be greater than 1800smq leading a vast area of the subject site to be developed for other purposes.

Tramway (subject to conditions) Low Trams run along Gordons Road but not along Mephan Street.

Warehouse (subject to conditions)

High Despite a number of restrictions, this would be a more likely Section 1 use to be established.

Section 2 ‘Permit Required’ uses:

Adult sex product shop

Low Due to the significant size of the subject site, this would be an unlikely primary use of the land.

Agriculture (other than Apiculture, Crop raising, Extensive animal husbandry, and Intensive animal husbandry

Low General agriculture would not be the highest and best use of the land in an urban setting


APPENDICES

Land Use Probability of Being Established

Comment

Education Centre Moderate There is no known demand for an education centre although based on the interfaces, this is a use that would theoretically be appropriate for the land and its context.

Industry High One of the few uses with a high probability although Clause 52.10 significantly restricts the type of industry that could be established.

Leisure and recreation (other than informal outdoor recreation, Major Sports and recreation facility and Motor racing track)

Low Defined as land used for leisure, recreation or sport, this would not be considered to be the highest and best use of this land.

Office Moderate The land is not on a major road and a major tenant or significant number of smaller tenants would need to be identified for office to be the primary land use.

Place of assembly (other than Carnival and Circus)

Moderate A place of assembly, such as a church or other religious building, could be established however the size of the land is significant and may too large.

Restricted retail premises Moderate - High Due to their larger format, a cluster of restricted retail premises could be established although the location is not considered to have sufficiently high exposure for it to be a viable location for such use.

Retail premises (other than Shop) Moderate A cluster of retail premises could be established although the location is not considered to have have sufficiently high exposure for it to be a viable location for such use.

Utility installation Low The land is too large for this to be the primary land use.

APPENDICES


APPENDIX 2

Production, use or storage (purpose) Buffer distances required from sensitive land use

Basic metal products including production of non-ferrous metals and works producing iron or steel products

100m – 1,000m

Chemical, petroleum and coal products including 100m – 1,000m

Fabricated Metal Products

(e.g. boiler makers, sheet metal production etc.)

100m – 1,000m

Food, beverage & tobacco

(e.g. abattoir, bakery, freezing / cool storage, poultry processing, milk depot, smallgoods production etc.)

100m – 500m

Miscellaneous Manufacturing

(e.g. leather goods, fibreglass, leather tanning, rubber production etc.)

200m – 1,000m

Non-metallic mineral products

(e.g. cement production, plaster production, glass production etc.)

100m – 1,000m

Other premises

(e.g. panel beating etc.)

100m – 300m

Paper & paper products 100m – 5,000m

Recreation, Personal & Other Services

(e.g. Commercial dry cleaners, commercial laundries etc.)

100m

Recycling and resource recovery Variable depending on specific use

Textiles

(e.g. carpet production, cotton dyeing, rope/twine production, treatment of textiles using carbon disulphide)

200m – 1,000m

Transport and storage

(e.g depot for refuse collection, storage of bulk volatile organic compounds, temporary storage of industrial waste, waste incineration)

100m – 1,000m

Wood, wood products, furniture

(e.g. joinery, sawmill, charcoal production etc.)

100m – 1,500m


APPENDICES

APPENDIX 3 – PHOTOGRAPHS OF SUBJECT SITE CONTEXT


APPENDICES

Picture 1 - Interface between Subject Site and No.1 Allara Avenue

Source: Google Earth

Picture 2 – View looking north from Mephan Street


Picture 3 – View looking south from Birdwood Street



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Picture 9 – View looking west along Birdwood Street


Picture 10 – Mephan Street frontage of Subject Site


Picture 11 – Western boundary of Subject Site



APPENDICES

APPENDICES


APPENDIX 4 – PROPOSED DPO SCHEDULE


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