E08. Kaufland Stores in Victoria Advisory Committee Epping. Request to be heard?:

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Kaufland Stores in Victoria Advisory Committee Epping E08 Request to be heard?: Yes Full Name: Organisation: Affected property: Attachment 1: Attachment 2: Attachment 3: Comments: Bernard McNamara BMDA Development Advisory Australia 181026 Submission 592-694_High_Street_Epping.pdf attached Submission Cover Sheet

Kaufland Stores in Victoria Advisory Committee 592-694 High Street, Epping Submission on behalf of Queensland Investment Corporation and Bevendale Pty Ltd, 1. This submission is made on behalf of the Queensland Investment Corporation and Bevendale Pty Ltd, the owners of the Pacific Epping Shopping Centre at 571-583 High Street, Epping (the Owners ). 2. The Owners strongly object to the proposed Amendment. The proposed Amendment is inconsistent with Plan Melbourne, the State and Local Planning Policy Framework, the Epping Central Structure Plan and the Activity Centre Zone Schedule 1 provisions. The proposed Amendment introduces inequitable planning and development outcomes within the Epping Central Metropolitan Activity Centre and is inconsistent with Planning Practice Note 46 and the purpose of the Activity Centre Zone and the Specific Controls Overlay. 3. The proposed Amendment is not strategically justified and will result in the underdevelopment of strategically located land within a designated metropolitan activity centre land. Approval of the Amendment would be an outcome which is inconsistent with the directions and provisions of Plan Melbourne 2017-2050, the State Planning Policy Framework and the Local Planning Policy Framework. 4. The use of a Specific Controls Overlay (SCO) is a poor planning outcome within the Epping Central Metropolitan Activity Centre, where the use and development of land is managed via State and Local Planning Policy, a detailed structure plan and the Activity Centre Zone Schedule 1 (ACZ1). The application of the SCO allows for the Kaufland development to avoid addressing the State significant planning objectives nominated in Plan Melbourne 2017-2050, the ACZ1 and the Epping Central Structure Plan. 5. The proposal is an underdevelopment of well-located Metropolitan Activity Centre land (within 500 metres of the Epping Railway Station) and is inconsistent with the Epping Central Structure Plan. The proposed Amendment will prejudice the delivery of a development outcome which is consistent with the strategic intention for the land as identified in the Structure Plan, being A significant opportunity exists to undertake comprehensive redevelopment of the existing Homemaker Centre site given its location on a major intersection, with ready access to Epping Station, the High Street Village and Epping Plaza. Collaboration between major land owners is required to ensure an integrated outcome. Redevelopment should incorporate a mix of uses at higher densities (including employment, retail and residential), public open space, a fine-grained pedestrian network and high-quality urban design. (Epping Central Structure Plan 2013, City of Whittlesea, pp.72) 6. The use of a Specific Controls Overlay within an Activity Centre Zone is contrary to fundamental zone structure given that the zone over which the SCO is to apply does not prohibit the proposed use but makes provision for such a use (subject to land use and built form assessments). 7. The application of the Specific Controls Overlay is an inappropriate planning process for the Site and is inconsistent with Planning Practice Note 46 Strategic Assessment Guidelines.

8. The short Explanatory Report is patently inadequate and provides no strategic justification for exempting the proposed Kaufland Site from the provisions of the existing Whittlesea Planning Scheme. including the ACZ1. The Explanatory Report does not meet a minimum standard for a strategic assessment for any planning scheme amendment. 9. The proposed Amendment will result in an inequitable planning outcome by exempting the owners of the Kaufland site from the built form provisions of the ACZ1, which other Epping Central stakeholders are required to address. 10. The Specific Controls Overlay process will allow Kaufland to avoid the payment of fees which would usually apply, being the Metropolitan Planning Levy and planning permit application fees. 11. It is clear that the Amendment is not strategically justified and proposed Kaufland development should be considered under a planning permit application which addresses the directions, objectives and design guidelines of Plan Melbourne 2017-2050 and the Whittlesea Planning Scheme. 12. The Advisory Committee should recommend the proposed Amendment be abandoned. Owner Landholdings 13. The Owners controls one of the largest landholdings in the Epping Central Metropolitan Activity Centre, which in total comprise approximately 34 hectares, consisting of Pacific Epping land at 531. 551, 571-583 High Street, 20 Jovic Road and 40 Deveny Road ( Pacific Epping ). These land holdings include undeveloped land to the south of the shopping centre, which has been approved for large format retail development. 14. Figure 1 illustrates the location of the Owners land holdings (bounded in black) in the vicinity of the Kaufland Site. 2

Figure 1: Owners Landholdings 15. Pacific Epping opened in the mid-1990s as Epping Plaza and following a series of expansions, now has approximately 220 stores. Major tenants include: Aldi, Best & Less, Big W, Coles, Harris Scarfe, Woolworths, Target, JB Hi-Fi and Dan Murphy s. 16. Pacific Epping contains major entertainment and food offers including the Readings Cinema complex, the Urban Diner street of restaurants together with associated retail, health and other service offerings. There are also community facilities such as the Council leased premises occupied by the Whittlesea Community Connections. A 96-room Quest all-suite hotel, offices and additional restaurants opened in July 2016. 17. Pacific Epping currently has approximately 75,000m2 of floor space of which approximately 52,000m² comprises shop floor space. In addition, there are approvals in place for Stage 6 (17,500m²), and large format complex of 16,500m2. 18. Since the adoption of the Epping Structure Plan by Council, the owners of Pacific Epping have actively invested within the Epping Central MAC (by way of development contributions as well as private investment) in order to support the strategic planning outcomes sought by Council for the Epping Central Metropolitan Activity Centre, including: (a) Urban Diner entertainment precinct - Permit 712797;(Built) (b) Costco (large format retail) Permit 714148; (Road and site works by the Owners) (c) Quest Hotel (mixed use residential hotel, office and retail) Permit 715949;(Built) (d) Southern Precinct (large format retail) Permit 715940; (approved) (e) 551 High Street, Epping (retail) Permit 716607;(relocation of Dan Murphy s; -Built) (f) Southern Carpark extension Permit 716674; (Built) (g) Extension of Main Road south to Deveny Road; (Built) (h) A new east-west road (Centre Road), connecting High Street to Main Road; and 3

(i) Deveny Road: A new 1km in length two-lane extension from Childs Road to Edgars Road Deveny Road works have included: New High Street/Deveny Road intersection including works to Childs Road and the railway level crossing; Completion of Deveny Road/High Street intersection to final form, including works to V R Michael Reserve; Construction of a new signalised intersection with the north-south road, centrally located; Replacement of all electrical, water and sewerage infrastructure along the Deveny Road alignment; and Construction of the full width culvert at Edgars Creek including environmental/landscape works to manage Growling Grass Frog habitat. It therefore cannot be stated by the proponent that there has been any lack of active investment in Epping Central. Through this investment Owners have increased the mix of land uses land use, have provided increased employment and have delivered critical infrastructure. In contrast, the proposal simply re-occupies an odd shaped land title, with the effect of removing for decades the prospects of the precinct achieving its planning objectives under the planning policies that apply. Planning and access issues that will arise from the Amendment. 19. The Amendment in its present form lacks strategic assessment as to the traffic and planning implications of the Amendment. From a review of the exhibited documents, the Owners have identified: a) significant planning, traffic and equitable outcome issues in exempting the development of the Kaufland Site from the standard planning permit application processes; and b) potential solutions to the issues raised for consideration and further action by the Planning Authority. 20. The Amendment fails to provide strategic justification for the application of the Specific Controls Overlay detail to enable this strategic analysis to take place and therefore: (a) (b) is inconsistent with Plan Melbourne, State and Local Planning Policy, the purpose of the Activity Centre Zone and the Specific Controls Overlay and Planning Practice Note 46 Strategic Assessment Guidelines. should be abandoned. BMDA Development Advisory 26 October 2018 4