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20130003 Moorabin Airport Planning Report Peer Review 8-2-13.docx

Moorabbin Airport Planning Report Peer Review Kingston City Council 8th February 2013

20130003 Moorabin Airport Planning Report Peer Review 8-2-13.docx

This report has been prepared for Error! No text of specified style in document.. SGS Economics and Planning has taken all due care in the preparation of this report. However, SGS and its associated consultants are not liable to any person or entity for any damage or loss that has occurred, or may occur, in relation to that person or entity taking or not taking action in respect of any representation, statement, opinion or advice referred to herein. SGS Economics and Planning Pty Ltd ACN 007 437 729 www.sgsep.com.au Offices in Brisbane, Canberra, Hobart, Melbourne, Sydney

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Moorabbin Airport Planning Report Peer Review

TABLE OF CONTENTS

1 INTRODUCTION 2 2 REVIEW 3 2.1 Assessment of proposal against 2010 Moorabbin Airport Master Plan 3

Land Use Policy 3

Precinct Policy 5

Land Use and Development 6 2.2 Local planning provisions – Kingston Planning Scheme 7

State Planning Policy Framework (SPPF) 7

Local Planning Policy Framework (LPPF) 18

Zones and Overlays 27 2.3 Conclusion 30

Moorabbin Airport Planning Report Peer Review 2

1 INTRODUCTION

SGS Economics and Planning (SGS) was commissioned to undertake a peer review of the Planning Assessment Report for the Major Development Plan for a Wesfarmers retail development at the Moorabbin Airport. The proposed development comprises:

retail uses

built form

vehicle and pedestrian access landscaping and sustainability

building and infrastructure services. The site is largely rectangular with a site frontage of 432 metres along Boundary Road to the east and a frontage of 115 metres along Centre Dandenong Road to the north with an area of 4.8 hectares. Table 1 details the proposed Wesfarmers development.

TAB LE 1. PROPOSED R ETAIL DEV ELOPME NT AND FLOOR SPACE

Use Use Sub-Category Retailer Gross Leasable Floor space

Net Retail Floor Area

Shop Discount Department Store

Kmart 6,640m2 5,693m2

Supermarket & Bottle Shop

Coles/ Liquorland 4,190m2 2,890m2

Bottle Shop 1st

Choice Liquor 1,104m2 922m

2

Total 11,934m2 9,505m2 Restricted Retail Premises

Office equipment and supplies

Officeworks 2,203m2 1,934m2

Industry Laundering, repairing, servicing or washing any article, machinery, or vehicle, other than on site work on a building, works or land.

K-Auto Shop 304m2 279m2

Total 14,441m2 11,718m2 Source: Aecom Planning Assessment Report, 2012

This review considers the responses as per the Planning Assessment Report, prepared by AECOM, in the context of the relevant policy. It focuses on the planning responses regarding the location of the proposed development, rather than those that relate to design. For each relevant policy, the review quotes the response as stated in the planning review, followed by a discussion on the accuracy of the interpretation.


2 REVIEW

2.1 Assessment of proposal against 2010 Moorabbin Airport Master Plan

Land Use Policy

AECOM

The Wesfarmers Group Project is a response to the key strategic policy considerations outlined in the 2010 Master Plan. It implements these considerations and in doing so contributes to the Vision for and viability of the Airport and the delivery of the Master Plan’s objectives. The policy landscape surrounding the operation of Airports has changed considerably over the last 10-15 years. Changes in Federal legislation have sought to encourage the primacy of Airports, recognising their contribution to local, state and national economies. Within this fabric is the need to achieve a relationship with land use on Airport land where land required for Airport operations (airside) activity and land outside of this (landside) to be used effectively and efficiently to maximise the operational and economic viability of the Airport. Specifically, the proposal:

introduces retail land uses that are encouraged and compatible with the 2010 Master Plan and the primary Airport use which will service the growing airport, local and regional populations. The proposal builds upon the Airport precinct’s established employment role, providing for approximately 55 direct and 90 indirect construction jobs, and future employment of 270 direct and 245 indirect jobs.

is a high quality design response that meets relevant design, siting and environmental guidelines and which is designed to comply with relevant height and siting standards to ensure the ongoing safety of airport operations;

provides for appropriate transport infrastructure on site and integrates with and builds on broader transport infrastructure, including supporting the provision for improved public transport services in the area;

efficiently utilises land in an urban setting that has access to all relevant infrastructure services and which can use these services with limited augmentation, including key traffic, drainage and other infrastructure in the immediate environs of the airport.

The proposal continues to be progressed in consultation with relevant authorities and stakeholders in line with established consultation processes. Further detail on the land use and design impacts and benefits of the proposal are detailed in subsequent sections of this report and in other Technical reports.

SGS

The vision of the 2010 Moorabbin Airport Master Plan is:

“To continue to develop an efficient and fully functioning airport of regional and state significance, supported and enhanced by quality land use, which will significantly contribute to


and improve and support the operation and growth of the airport and the economic and social base of south eastern metropolitan Melbourne, particularly its local community.”

The master plan highlights that Moorabbin Airport is the third busiest airport in Australia. The key driver of the airport is aviation, supported by a mix of aviation and commercial land use activities. As the master plan discusses the opportunity for the provision of a Coles Group development on the airport site, the proposed development is consistent with the master plan. Notably, the master plan does not indicate the size of the proposed retail development. However, nominating a large DDS development on the airport site contradicts many of the objectives set out in the master plan, specifically those that address the airport’s critical aviation and employment roles. These include:

To support land use which, other than Moorabbin Airport, could not generally be developed within the wider Kingston region.

To maximise the opportunity presented by the Airport precincts’ excellent access to the surrounding road network and proximity to a strong (and growing) labour force to improve the supply of local employment opportunities.

To build on and advance the Airport precincts’ established employment role. Other objectives set out in the master plan, but not considered in the planning response, include:

To support the co-location of engineering and avionics services and other aviation business and related land use,

To build on opportunities in the aviation precinct and the wider region to facilitate appropriate research and land uses through links with key industry education and training organisations,

To provide activities and services, including office, industrial, retail and commercial/business uses. These objectives highlight the specialist functions of the airport and the importance of protecting and enhancing these functions in the future. Furthermore, they aim to improve the supply of local employment opportunities. The proposed retail development, with a 11,718 square metre net retail floor area, is a substantial development, one which is taking up scarce employment land. State and local policy identifies the limited employment land within the south east of Melbourne. Additionally, the master plan notes that reservations for the proposed Mornington Peninsula and Dingley Freeways are located within 500 metres of the airport. In addition to the industrial zoned land directly to the east of the proposed retail development, the future freeway will serve as a physical barrier between the development and the nearest residential area of Dingley Village. Dingley Village is already served by the Dingley Village Neighbourhood Activity Centre. Figure 1 shows the Indicative Land Use Plan for the airport.


F IGURE 1. IND ICATIVE LAND USE PLAN, MOOR ABB IN AIRP OR T

Source: Aecom, Planning Assessment Report, 2012

Precinct Policy

AECOM

The proposal is a direct response to, and an implementation of, the key Objectives and the Relevant Strategies outlined for Precinct D. Specifically the proposal:

continues to develop the precinct as a strong employment activity node, and provides services and facilities for the growing employee population at the Airport and in the region.

provides for additional employment opportunities for the region linked to the Principal Public Transport Network.

recognises and supports existing industry, warehouse, office and commercial activities. promotes a design that continues the high profile, high quality landscaped environment already in

part established on the site.

is designed to:

encourage provide strong pedestrian linkages to the Principal Public Transport Network and to other pedestrian networks in the area.

protect airside and aviation activities by ensuring the appropriate siting and design of all buildings and infrastructure.

have regard to the interfaces with other precincts and non-airport land. The Proposal has minimal amenity impact on the Airport or other nearby land uses, and only a limited and reasonable impact on other retail activity centres in the region. The proposal is likely to provide increased amenity by way of employment, improved access to services and increased competition. These benefits also bring direct benefit to the locality and the economy of the region. The specific Economic and Social impacts and benefits of the proposal are discussed in more detail in subsequent sections of this report, and in even greater detail in the respective Technical reports.


recognise the Mordialloc Settlement Drain reserve.

SGS

The priority for Precinct D is for a strong employment node that provides services and facilities for the growing employee population at the airport and in the region and that is connected to the Principal Public Transport Network. The planning response fails to mention the findings of the associated Integrated Transport Plan, that while the site is serviced by two bus routes, only one is currently operating to a full timetable. The other only operates during peak times. Recommendations to increase services on this route have been made, however no funding has been allocated to make this a reality. Again, proposing a DDS retail development of this size appears to contradict the vision for a strong employment node for the airport and for the precinct. These objectives would be better achieved by strengthening aviation and commercial employment.

Land Use and Development

The Special Use Zone – Schedule 2 Zone purpose

AECOM

The proposal is consistent with, and implements the purposes of the SUZ 2 zone. Specifically the proposal:

is consistent with the relevant policy as described and discussed in Section 6.1. 6.2 and 6.3 of this report.

supports the operation of the site for aviation related uses, and will provided better services and infrastructure for existing Airport landside and airside uses, and

provides for retail land uses which further reinforce the employment and business imperatives of this precinct, bringing some 55 direct and 90 indirect construction jobs and future employment of 270 direct and 245 indirect jobs.

SGS

The planning response lists all purposes of the Special Use Zone Schedule 2 which are:

To provide for the use and development of the land in accordance with the Moorabbin Airport Land Use Policy.

To encourage the development of aviation related uses.

To encourage the development of commercial, retail, business and office uses.

To establish strong employment and business precincts and maximise employment opportunities. The planning response claims that it is consistent with relevant land use policy, precinct policy and land use and development policy on the basis that the proposed retail development will help to service the employees of the airport and will help to create additional employment. As per our comments above on responses to land use policy, precinct policy and land use and development policy, the planning response fails to adequately consider the specialist function of the airport and how a large retail development, such as the one proposed, will affect the supply of already scarce employment land in Kingston and the south east.


Table of uses

AECOM

The proposal provides land uses that are consistent with the zone provisions. All but the proposed Officeworks (Restricted Retail) are land uses that do not require a planning permit. The Officeworks (Restricted Retail) component of the proposal is a discretionary activity requiring planning approval, and assessment under the Master Plan, Implementation Framework and Decision Guidelines is required to be considered in light of the Use of Land provisions detailed below. An economic assessment and a planning assessment of the entire proposal follows later in this report, supported by a separate and more detailed economic impact and benefit assessment Technical report.

SGS

As the AECOM planning response notes, the Officeworks development is not an as of right use and requires planning approval. Clause 21.06 of the LPPF aims to provide for the long term sustainability of Kingston’s restricted retail precincts. Strategies to achieve this aim to reinforce the existing restricted retail precincts in Moorabbin, Cheltenham, Mentone, Parkdale and Heatherton, and to encourage consolidation of restricted retail precincts by preventing any new restricted retail development outside the existing precincts unless located in a designated activity centre. As the site is not located in an activity centre it is not compliant with local policy.

2.2 Local planning provisions – Kingston Planning Scheme

State Planning Policy Framework (SPPF)

AECOM

The high level objectives provided above set the framework for more specific and detailed policy and standards that articulate these aspirations at different levels of detail and across a broad range of policy issues and land uses. Matters requiring planning approval and consent often raise benefits and disbenefits, and the planning authority, be it government, a regulated authority or an appeals body is required to make a decision balancing these factors. The following sections assess this proposal against State policy, local policy and relevant particular provisions in this vein.

SGS

The planning response includes most of the relevant high level objectives of the State Planning Policy Framework (SPPF). Notably, an objective of the SPPF is “to balance the present and future interests of all Victorians”. Given the specialist nature of the Moorabbin Airport, its surrounding industrial and non urban land to the east and south, and the scarcity of employment land in the south east of Melbourne, it is questionable


whether the best use of this site is for a large DDS retail development. It would be in the best interest of current and future Victorians to very carefully assess what is developed on this site. Settlement Policy

AECOM

The proposal raises issues of impacts and benefits which are considered in greater detail in subsequent sections of this report, and in explicit detail in separate Technical Reports (i.e. Economic impacts). This section in essence provides an overview of those specialist investigations as they are relevant to local policy and provisions. The Airport site is well serviced by existing settlement patterns and an array of transport, communications, physical and social infrastructure. Specifically, the proposal:

maintains the required health and safety provisions of the operating Airport; is well designed, providing for safe pedestrian and vehicular movements within the site, whilst

integrating safely with pedestrian and vehicular networks outside the site;

provides for pedestrian connections to existing land uses on the Airport site and to existing pedestrian networks external to the site, facilitating walking and pedestrian access to the site;

adds to the diversity of choice for residents and employees in the area by providing alternate retail land uses to those found locally and modest competition for existing similar land uses in the region bringing benefit to these residents and employees by way of convenience, diversity and choice;

adds to the depth and strength of the local and regional economy by introducing alternate retail land uses to those found locally that have a limited and reasonable impact on other similar uses in the region;

provides a high quality design response to the site, significantly uplifting the site’s contribution to the urban design and amenity of the locality, but which also captures opportunities for better access and connectivity;

is well located and designed to provide for a sustainable development which is located on the Principal Public Transport Network and which also provides a local service to existing residents and a significant number of employees in the region who presently have to travel some distance for similar services and which adopts proper design and management measures to prevent the pollution of land, water and air and protection of environmentally sensitive areas and natural resources; and

integrates well with and takes advantage of existing and proposed transport networks, including public transport services along Centre Dandenong Road and Boundary Road.

SGS

While the planning response sets out the relevant settlement policy, the response does not provide a thorough interpretation of the policy. The clause states 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.” Many policies have identified the existing scarcity of employment land within the south east region of Melbourne and the importance of ensuring that any appropriate land be used for this purpose to meet the needs of the future population. As Kingston residents are becoming more qualified and highly educated, it is important that there are appropriate jobs on offer in the local area, which will help to reduce travel times, a priority of the Metro Strategy Discussion Paper. While the proposed retail development may provide diversity of choice for retailing within the local area, the development is not appropriately located (see activity centres policy below).


The planning response claims that the site is well connected to public transport networks. However, the Integrated Transport Plan accompanying the report states that of the two bus routes servicing the site, one route is not operating as required. Activity Centres

AECOM

Moorabbin Airport is a consolidated activity area generating significant activity on airside and landside precincts the airport provides many of the characteristics of an activity centre. While it fits within the definitions, it is not a designated Activity Centre. The Airport provides many of the characteristics typical of an activity area. It is a substantial employment node and provides:

Approximately 3,300 direct jobs 50 aviation businesses

40 non-aviation businesses

11 flying schools. Moorabbin Airport also has a busy and diverse mix of business, retail and service uses that generate a high number of trips. The site is generally well serviced by public transport routes and is located on the Principal Public Transport Network. Moorabbin Airport shares similar characteristics to the various Specialised Activity Centres identified in the SPPF and it plays a key role in the local and metropolitan economy. The activity generated by the Airport has a positive impact and acts as a stimulus and economic multiplier to other businesses and activities in the locality and region. The proposed Wesfarmers Group Project adds further to this mix, and provides for land uses which complement and support the existing Airport operation. It will support and add to services offered to the local and regional community with a limited and reasonable impact on existing activity centres. The Economic Impact and Social Impact Assessments explore these impacts in significant detail. The Activity Centre objectives of the SPPF are met by the following economic benefits attributable to the proposed development:

greater retail choice and accessibility to the Main Trade Area (MTA) residents and an improved level of retail price competition

provision of an activity area which helps meet a market gap for higher-order major retail tenants such as a Discount Department Store, a large-format liquor store and large-format stationery supplies

greater employment self-sufficiency in the MTA through local employment generation, and opportunities for people to enter the workforce through the retail sector as an employment “gateway", and

short term construction employment and an increased range of permanent jobs with opportunities for the local community

In this context, there is a strong argument that Moorabbin Airport already functions as an Activity Area, and that it should be formally recognised as an Activity area. The proposed development will bring a net benefit to the local and regional community with limited and reasonable impacts on other activity centres in the region.

SGS

While the planning response seeks to set out the relevant Victorian activity centre policy and objectives, the interpretation of the policy is not robust.


State activity centres policy dictates that development should be contained within activity centres and that a network of centres should be created. Activity centres should be built up as a focus for high quality development, activity and living for the whole community. Due to its primary aviation role and the safety implications and the land conservation measures necessary to protect this function, Commonwealth, State or local policy dictates that residential development will never occur adjacent to Moorabbin Airport. The airport is not currently an activity centre and will not be an activity centre in the future. The planning response highlights that the Moorabbin Airport has the characteristics of an activity centre and uses this as the basis to argue that the proposed retail development is compliant with State and local policy. The AECOM position ignores one essential feature of an activity centre, which is a central location in a residential catchment. This is not the case in the centre of the Green (non-urban) Wedge. The Moorabbin Airport is not formally identified as an activity centre within the activity centres hierarchy. As such, State policy recognises the proposed development as an ‘out of centre’ development. It is therefore not compliant with State policy or local policy (see next section). The planning response argues that the Moorabbin Airport should be recognised as a Specialised Activity Centre. Clause 11.04-2 states that any development at Specialised Activity Centres should be consistent with the primary specialist function of the centre. Even if the Moorabbin Airport was classified as a Specialised Activity Centre, the proposed development would not comply given that a 11,700 square metre retail space is not consistent with the primary aviation function of the airport. Nor would it be “of particular importance to the State’s innovation” as is the requirement for a Specialised Activity Centre under this clause. A further objective relating to activity centre planning aims to encourage the concentration of major retail, residential, commercial, administrative, entertainment and cultural developments into activity centres which provide a variety of land uses and are highly accessible to the community. The proposed retail development is on the eastern boundary of the Moorabbin Airport, which is surrounded by green wedge zoned land to the north, industrial land to the east and south and the airport to the west (see Figure 6). The site does not abut any residential areas. As such, as well as being an out of centre development, the proposed retail development is poorly located in terms of surrounding land use and accessibility. Clause 11.04-5 Melbourne’s Urban Growth aims to set clear limits to metropolitan Melbourne’s urban development. The urban growth boundary to the north of the site dictates that the proposed retail development will not have a catchment to its north. The Green Wedge

AECOM

The objective of this clause is to protect the green wedge and ensure that long term strategic planning of each green wedge area occurs to promote and encourage its key features and related values. As Moorabbin Airport is Commonwealth land, it is not subject to the Victorian Planning System. It is unzoned land. Green wedge land sits opposite the site on the northern side of Centre Dandenong Road (refer also Section 7.4.9 of this report). It is also noted that green wedge policy seeks to plan for and protect major transport facilities that serve

the wider Victorian community, such as airports and ports with their associated access corridors.

SGS

The Green Wedge Zone aims to protect green wedges of Metropolitan Melbourne from inappropriate development.


The planning response wrongly dismisses the nearby Green Wedge Zone, claiming that it is not relevant as the Moorabbin Airport lies on Commonwealth land. However, the presence of the green wedge, just to the north of the proposed site, dictates that the land is recognised as valuable as it protects the airport and related flight paths and that it should be protected for the long term. It is logical that development on land adjacent to green wedge land should not compromise the protection of the airport and its activities. However, a development the size of the proposed retail development at Moorabbin Airport may do just that. Furthermore, the airport’s location near the green wedge, and the nearby urban growth boundary to the south east of the site, indicates the limited population growth that can occur in the surrounding area. This limits demand for retail provision. Economic Development

AECOM

Planning is to contribute to the economic well-being of communities and the State as a whole by supporting and fostering economic growth and development. The proposed development complies with the requirements of Clause 17 by meeting the community’s needs for retail and services, whilst providing a net community benefit in relation to accessibility, efficient infrastructure use and sustainability of commercial facilities. The existing Airport functions as a key employment area providing some 3,300 direct jobs and 6,000 indirect jobs. This is anticipated to grow to 7,500 direct jobs upon full implementation of the approved Master Plan (2010). The Wesfarmers Group Project will deliver a variety of local and regional benefits including additional employment, services and competition. Currently, there are eight (8) Woolworths supermarkets in the Main Trade Area compared to only two (2) Coles supermarkets. As discussed in the Economic Impact Assessment, the proposed development reflects an identified market gap and is located on one of the few remaining sites of a size and location that can accommodate the proposed development. The Economic Impact Assessment (Essential Economics, 2012) and the Social Impact Assessment (Environmental Affairs, 2012) reports explore these impacts in some detail, however the following key conclusions emerge from these reports:

The Wesfarmers Group Development will be a higher-order retail centre containing a selection of large format major retail traders in one integrated and master-planned development. Traders include a Kmart discount department store (DDS), Coles full-line supermarket including Liquorland, 1st Choice large-format liquor store, Kmart Auto retail motor accessories and Officeworks large-format office and stationery supplies.

The development scheme reflects an identified market gap associated with the relative lack of major retail traders serving the surrounding suburbs. Furthermore, the subject site is one of few available sites of the size and location that can accommodate the significant land requirements of these large-scale retail formats.

The focus of the Wesfarmers Group project development scheme is on a selection of large-format major retailers only, and this means that the centre will serve a functional role that is different from other retail activity centres of similar size which have a lower provision of major retailers and a higher provision of specialty shops.

A Main Trade Area (MTA) has been defined for the project which reflects the broad trading patterns associated with the proposed retail formats, and the potential synergies with other uses at Moorabbin Airport which attract people from a wide geographic area. In 2011, the population of the MTA is estimated at 151,530 persons. Ongoing population growth is forecast for the MTA, with a population of 166,900 persons forecast by 2024. This represents a total increase of 15,370 residents at an average growth rate of 1,180 persons per annum.


This existing employment base at Moorabbin Airport of 3,300 jobs provides an additional source of patronage for the proposed Wesfarmers Group project. In addition to the direct employment located on-site at Moorabbin Airport, an estimated additional 16,500 jobs are located in the adjacent industrial and commercial areas of Braeside, Dingley and the light industrial precinct adjacent to Grange Road. Moorabbin Airport is also used by approximately 800 students at flying schools located on airport land.

A review of the retail provision in the region has highlighted:

current lack of choice for consumers, noting the large number of Woolworths supermarkets in this part of Melbourne

the dominance of Southland in the retail hierarchy serving the region the lack of alternative destinations for DDS shopping outside of Southland and more distant centres

the differentiation of the Wesfarmers Group project with the role and function of neighbourhood centres such as Dingley and Thrift Park.

An opportunity exists for the Wesfarmers Group project to trade successfully based on the results of a market assessment. A relatively high 21% share of sales are expected to be derived from non-MTA residents in view of the high local workforce population, synergies with other airport uses (including the existing DFO) and the relative lack of DDS shopping options in this part of Melbourne.

Economic impacts are expected to be minimal. The economic impact assessment shows that the overall impact on the 16 selected centres in 2014 associated with the proposal is a 2.3% impact on the total turnover that these centres would have achieved in 2014 without the proposal proceeding. Although some impact on the level of turnover of surrounding centres is anticipated, these impacts are considered to be within the bounds of a normal competitive retail environment. In this regard, trading impacts of between 10% and 15% are generally accepted as the level of impact where a proposed new or expanded retail development or centre needs to be carefully assessed for potential negative outcomes on existing centres.

The proposed Wesfarmers Group MDP is consistent with the approved Airport Master plan which envisages retail development for the subject site. The MDP also supports strategic land use policy objectives related to employment and investment at the Moorabbin Airport specifically (Kingston Planning Scheme), and in suburban areas of Melbourne more generally (Melbourne 2030 and Melbourne@5Million). According to the forecast economic impacts associated with the Wesfarmers Group MDP (see points above), the proposal will not undermine the role and function of existing activity centres in the City of Kingston and is therefore consistent with the objectives of the Kingston Retail/Commercial Development Strategy. The proposal is also expected to generate a relatively low and one-off trading impact for centres in adjacent municipalities, including Greater Dandenong and Glen Eira.

Economic benefits associated with the proposed Wesfarmers Group Development include:

construction investment of $25 million a total of 55 direct jobs created during the construction phase of the project, with approximately

90 indirect jobs created in the wider economy through the employment multiplier

at full development an estimated 270 direct on-site jobs are expected to be created on an ongoing basis, with an additional 245 indirect ongoing jobs created through the wider economy as a result of the employment multiplier

a high share of employees are expected to live locally

enhanced shopping and service facilities for local residents, workers and visitors

providing a centre which helps meet a market gap for higher-order major retail tenants such as a DDS, large-format liquor store and large-format stationery supplies

an opportunity to reduce the need for residents in the MTA to travel to larger and more distant centres at Southland, Parkmore, Chadstone, Dandenong and Frankston in order to undertake basic comparison shopping (apparel, homewares etc.), while not undermining the ability of these centres to continue to service the higher-order retail needs of the MTA population

ability to achieve greater employment self-sufficiency in the MTA through local employment generation, and to provide important opportunities for young people to enter the workforce through the important role of the retail sector as an employment “gateway"

creation of an additional revenue stream for Moorabbin Airport which contributes to the maintenance and investment in aviation infrastructure.


The potential adverse social impacts identified all relate to possible perceptions or concerns about aspects of the approval and operation of the proposed development. The Social Impact Assessment assesses these in detail, including all impacts and related mitigation measures about which people may have concerns. The overall conclusion of this assessment is that possible perceptions or concerns about aspects of the proposed development are largely unfounded and that the proposed retail development at Moorabbin Airport is likely to result in a number of social benefits for the local and regional area – particularly related to the increase in the availability and accessibility of retail resources and increased job opportunities – particularly jobs that are part time and/or with flexible hours. Further, the proposal will bring significant benefit to the local and regional community with only limited and reasonable impacts on the community or on other activity centres in the region. In this context, there is a very strong argument that the MAC should already be formally recognised as an Activity Centre or as a Specialised Activity Centre. Should this development be considered to be an ‘out of centre development’, the accompanying Social and Economic Impact Assessment reports detail the likely need for, impact and benefit of this proposal on the locality and region. The proposed development brings a variety of local and regional benefits without unreasonable or unusual detriment to other land uses or users. The net benefit to the local and regional community outweighs any net disbenefit, providing additional employment, service and competition.

SGS

While the planning response considers some of the State policy regarding economic development, it does not adequately interpret the policy, ignoring the fact that the centre is an out of centre development. The economic development policy states that:

“Planning is to contribute to the economic well-being of communities and the State as a whole by supporting and fostering economic growth and development by providing land, facilitating decisions, and resolving land use conflicts, so that each district may build on its strengths and achieve its economic potential.”

The planning response is focussed on the benefits that the retail development will have on local employment, competition, airport revenue and self sufficiency. What the response fails to recognise is that developing a DDS on the Moorabbin Airport site hinders the airport from building on its strengths as a centre for aviation and related services. Clause 17.01-1 relates to business. The objective is to encourage development which meets the communities’ needs for retail, entertainment, office and other commercial services and provides net community benefit in relation to accessibility, efficient infrastructure use and the aggregation and sustainability of commercial facilities. Strategies to achieve this include:

To locate commercial facilities in existing or planned activity centres To provide new convenience shopping facilities to provide for the needs of the local population in

new residential areas and within, or immediately adjacent to, existing commercial centres The proposed retail development is neither in an activity centre or adjacent to an existing commercial centre and therefore does not comply with this policy. 17.01-2 aims to manage out of centre development in Metropolitan Melbourne. Strategies to achieve this objective are quoted in planning response and include ensuring that:


Proposals or expansion of single use retail, commercial and recreational facilities outside activity centres are discouraged by giving preference to locations in or on the border of an activity centre.

That out of centre proposals are only considered where the proposed use or development is of net benefit to the community in the region served by the proposal.

Again, the Moorabbin Airport is not an identified activity centre, thus the proposed development is discouraged under this policy. The 2010 Moorabbin Airport Master Plan specifically refers to the potential for retail development in the north-east of the airport site and mentions that the proposal for a Coles Group development, including supermarket, discount store and restricted retail premises. In this respect, the planning response is compatible with the airport master plan. However, while the master plan does indicate that some retail is allowed in Precinct D, it does not propose or prescribe the size of retail. The 2010 Moorabbin Airport Master Plan highlights that the Moorabbin Airport is the third busiest airport in Australia. It also states that Kingston is a significant location for regional job provision compared to some other municipalities within the region. The airport site, centrally located in the south east region, represents one of the few remaining large scale land use and employment opportunities in Kingston and the surrounding area. There are very limited opportunities that can provide for and match the kind of land use that can be accommodated within the airport precinct. The master plan acknowledges the potential for the airport to develop into an aviation and business precinct of a regional scale. The Chifley Business Park, located on the airport site to the west of Precinct D and the proposed retail development, has supported the expansion of local companies that would otherwise have had to leave the region. This highlights the potential for the airport site to help strengthen employment opportunities in the south east. This is critical, especially due to the scarcity of employment land in this region. Increasing the employment capability of the site, via aviation and commercial business park related employment, would also help to reduce journey to work times for local residents. Transport

AECOM

The proposed development has direct frontage to two arterial roads and is located on the Principal Public Transport Network, Principal Freight Network and Principal Bicycle Network. The accompanying Traffic Impact Assessment and Integrated Transport Plan prepared by GTA confirm that the proposed development appropriately manages its impacts through various upgrades to the local road network and is readily accommodated on the local and regional network. The proposed development facilitates alternative modes of transport through incorporating the provision of public transport, pedestrian and cycling infrastructure. As discussed further below, the proposed development has sufficient car parking provision in accordance with Clause 52.06 of the Kingston Planning Scheme. The accompanying Integrated Transport Plan (ITP) technical report confirms that the site manages its impacts well internally, is readily accommodated on the local and regional network, and has excellent access to trunk road networks. The proposal takes advantage of existing public transport services (it is located on the PPTN) and will add to the demand for and the viability of those services. The ITP proposes a number of contemporary measures and initiatives to maximise the efficiency of the operations of the site, and sustainability initiatives to integrate with and support existing transport networks, to minimise the need for people to travel and when they do, to reduce reliance on private vehicles in favour of other, more sustainable alternatives.


The proposed development seeks to encourage walking and cycling by the provision of paths around the perimeter of site, as well as the provision of on-site bike storage and change room facilities.

SGS

The planning response correctly states the overall objective for State transport policy, however, has not thoroughly considered the impacts of the proposed development and omits some of the findings of the Integrated Transport Plan regarding access to the site via active transport. Critically, AECOM’s planning response does not give reference to the findings of the Integrated Transport Plan, that “given the site location, it is considered likely that “car as driver or passenger” may be higher for Kingston overall, and sustainable transport modes may be lower.” The table below indicates the existing and target travel mode split targets for the site set out in the Integrated Transport Plan.

TAB LE 2. MODE SPL IT TAR GETS

Mode Existing Target

Walking and cycling 3% 6%

Public transport 3% 6%

Car as driver or passenger 93% 86%

Other 2% 2% Source: GTA Consultants, Integrated Transport Plan, 2012

The National Aviation White Paper (2009) states that:

“Major metropolitan airports play a significant role in the transport networks of the cities in which they are located and are responsible for generating a significant number of vehicle movements. Airport developments that significantly increase the number of airport users can have a substantial impact on the surrounding transport infrastructure, increasing urban congestion and vehicle emissions and reducing the efficiency of the surrounding transport network”.

The aim of Clause 18.01-1 Land Use and Transport Planning is to create a safe and sustainable transport system by integrating land use and transport. A strategy to achieve this objective is to ensure access is provided to developments in accordance with forecast demand, taking advantage of all available modes of transport and to minimise adverse impacts on existing transport networks and the amenity of surrounding areas. The proposed development will contain 537 car parking spaces. The traffic that a car park of this size can generate has the potential to reduce the efficiency of the surrounding transport network, including the operations of the Principle Freight Network. The existing walking and bicycle network around the site is poor (see Figure 2 below). The site is currently serviced by two bus routes (828 and 705) and an additional bus stop may be developed on Boundary Road, adjacent to the site. The Integrated Transport Plan notes that while the route 828 bus service provides a regular service, the route 705 bus only runs on a limited service in the morning and afternoon peak periods between Monday and Friday. The plan notes that due to its limited service this bus route “cannot provide the flexibility afforded by a private vehicle.” A transport review recommended that the frequency of services on the 705 route be increased, however, the recommendations of this review have not been adopted as policy and there has been no commitment to funding upgrades. A timetable for implementation has not been implemented.


The Integrated Transport Plan states that the site is adequately serviced by walking facilities and that some workers living nearby may choose to walk to the site. It also states that, “the draft Principle Pedestrian Network methodology (under preparation by the Victorian Department of Transport) finds that people will routinely walk up to 2km to access significant activity centres, employment or public transport.” Other than Dingley Village, there are very few residential areas located within a two kilometre walk of the proposed development. It is therefore unlikely that many workers will walk to work and that driving will continue to be the primary mode of transport used to get to the site. The development of land reserved for a future freeway to the east of the site will also likely reduce pedestrian activity between the site and Dingley Village.

F IGURE 2. E XIST ING B ICYCLE AND WALKING NE TWOR K

Source: Kingston Cycling and Walking Plan

Airports

AECOM

The proposed development complies with Clause 18.04 by supporting and complementing the aviation operations at the site. The land uses and development proposed by the Wesfarmers Group Project complements the operation of the Airport in a variety of ways, including:

supporting its viability and in doing so its role in the Victorian network of airports through the provision of compatible land uses

providing a revenue stream which will support long term investment in Airport infrastructure and ongoing operations

connecting to the airport and provides services to the on-airport population.

providing employment opportunities for flight students. supporting the growth and needs of airport users, the Chifley Business park and land side activities. supporting Airport’s key existing role in a local and regional activity area and focus of commercial

and airport activity, and

providing a “benign” land use neighbour for core Airport activity.


The proposal is a planned outcome of the three approved Master Plans prepared for Moorabbin Airport. These Master Plans are required to, as their primary outcome, protect and enhance airport operations at the site. The proposal recognises and protects the operational needs of the Airport. In this context, the proposal strengthens the operation of the Airport and is consistent with State policy. An Aviation Impact Assessment (Kneebush Planning and Rehbein Airport Consulting) of the effect that the proposed development may have on aircraft operations due to building generated windshear and turbulence has been prepared and is provided in Part B of the MDP. The MDP also includes a response to other potential impacts to airport operations. Both of these assessments found the proposed development will not impact on aircraft operations at Moorabbin Airport.

SGS

The planning response acknowledges the relevant State airport policy. Clause 18.04-2 Airports has the objective to strengthen the role of Victoria’s airports within the State’s economic and transport infrastructure and protect their ongoing operation. Strategies to achieve this objective include:

Protect airports from incompatible land uses.

Ensuring the planning of airports identifies and encourages activities that complement the role of the airport and enables the operator to effectively develop the airport to be efficient and functional and contributes to the aviation needs of the State.

Recognise Moorabbin Airport as an important regional and State aviation asset by supporting its continued use as a general aviation airport, ensuring future development at the site encourages uses that support and enhance the State’s aviation industry and supporting opportunities to extend activities at the airport that improve access to regional Victoria.

The planning response focuses on the proposed development as being necessary to serve the needs of airport employees and users. However, this contradicts State policy regarding Moorabbin Airport – that any future development at the airport should support and enhance Victoria’s aviation industry and support opportunities to improve access to regional Victoria. Other State Guidelines, Plans and Strategies

AECOM

The Victorian Government has committed to a new Metropolitan Planning Strategy for Melbourne by 2013, to replace Melbourne 2030 and Melbourne@5million. The Metropolitan Strategy is currently under development by the Department of Premier and Cabinet and the Department of Planning and Community Development. The new Metropolitan Strategy is being prepared with input from the Department of Transport, VicRoads, the Growth Areas Authority and other Agencies. The Discussion Paper released in October 2012 promotes a number of key principles and strategic directions of relevance to the Wesfarmers Group Project. These are:

Recognising and supporting the critical role of employment and employment precincts in underpinning a competitive economy;

Enabling greater (and local) access to services and employment within a notional ’20 minutes’ travel time, and

Supporting infrastructure investment and a greater alignment between infrastructure investment and broader, transformational metropolitan planning objectives.

Map 11 of the Discussion Paper notes Moorabbin Airport as a key location of major employment

concentration in Melbourne.


SGS

One of the focuses of the Metro Strategy Discussion Paper is on employment and ensuring that residents of Melbourne have fast and easy access to employment and services and live within a ’20 minute’ city. The discussion paper specifically identifies that commuting times and distances are in danger of blowing out due to the disconnection between housing and jobs and it is therefore important to protect employment land in the south east. The paper highlights Moorabbin Airport as a significant employment node within Melbourne. Principle 6 within the strategy states that activity centres have traditionally been based around retail, however, in terms of planning Melbourne’s overall form, the strategy should now focus on jobs as the starting point. To achieve this, the strategy recommends unlocking capacity in established areas for employment and housing. Given that the airport is already recognised as a significant employment node within Melbourne, this highlights the strategic importance of the Moorabbin Airport as a site for the growth of future employment in the south east, especially given the scarcity of employment land. The discussion paper highlights that growth within Melbourne needs to be placed within the wider context of regional cities. As Kingston has one of the most concentrated industrial sectors in Australia and one of the highest manufacturing output levels of any Victorian city, it makes sense that any land use or development within this area should align with these uses so that the full potential of these sectors can be realised. It is unclear how the proposed DDS development enhances either aviation or industrial and manufacturing operations.

Local Planning Policy Framework (LPPF)

Clause 21.02 Municipal Profile

AECOM

The Municipal Profile recognises that Kingston’s regional significance is heightened by the presence of the Moorabbin Airport, which is recognised as one of the busiest airports in Australia and one which plays a major role in the State’s economic and transport infrastructure. It is also acknowledged that land which is not required for aviation purposes is increasingly being used for a diversity of retail and commercial activities. The proposed development is consistent with the referencing contained within the municipal profile. The Airport is clearly recognised as an important contributor to local, regional and State economies, and in achieving this, a land use that elevates the regional significance of the City of Kingston. The Clause notes that land which is not required for aviation is increasingly being used for a diversity of land uses including retail and commercial activities.

SGS

The municipal profile recognises the regional significance of Moorabbin Airport. It also acknowledges that the long term protection of flight paths is necessary to ensure future growth of the airport reaches its full potential. The response fails to mention that the municipal profile states that “based on future growth forecasts the airport is likely to play an increasingly significant role within the region and should therefore be protected from development which may constrain its potential for future growth.” As the primary role is aviation, a retail development of this size has the potential to inhibit the airport from reaching its full potential (in its primary aviation role and associated employment).


While the municipal profile does state that land not required for aviation purposes at the Moorabbin Airport is becoming increasingly utilised for a diversity of retail activities, it is not stated whether this retail development is desirable. The planning response considers this statement in the context that it is desirable. This statement should not be interpreted as a direction from the Council’s policies. In addition to aviation use, the response fails to mention the importance of industry/ employment as highlighted in the municipal profile: “Kingston has the highest concentration of manufacturing employment in metropolitan Melbourne and is therefore a major provider of jobs to the south-east metropolitan region.” Due to the decline of manufacturing in other locations in Melbourne, and competition with the west of Melbourne, supporting the manufacturing industry via complimentary employment uses should be a priority. It is possible that employment that is complimentary to aviation or manufacturing be located on the site.

Further SGS Comments

Clause 21.03 Land Use Challenges for the New Millennium The planning response did not consider this clause. The clause considers land use challenges for the new millennium and states that despite modest population growth there has been substantive change in the retail sector in Kingston, specifically Southland, Moorabbin Airport and in homemaker centres at Moorabbin. The clause states that “ensuring that future planning decisions prioritise the facilitation of retail investment into Kingston, activity centres will be vital in successfully achieving metropolitan planning objectives.” Thus, the LPPF states the importance of investing in activity centres to achieve metropolitan planning objectives. The proposed development at Moorabbin Airport is an out of centre development and thus is also against metropolitan planning objectives. Clause 21.04 Vision While the planning response includes the Kingston Strategic Land Use Plan (see Figure 3 below), it does not discuss the plan and its implications. These include that:

The Moorabbin Airport is not identified within the activity centre hierarchy in the Strategic Land Use Framework.

The closest residential area to the site, Dingley Village, is only nominated as an area for incremental housing change. Other locations in the municipality, those which surround the identified principal and major activity centres located along the coast, are promoted as areas for the promotion of increased housing diversity. Of the residential opportunity sites set out in the land use plan, none are located with easy access to the site. The Retail and Commercial Land Use Framework Plan (Clause 21.06) opportunities for medium density housing only around identified activity centres.

This not only confirms that local policy recognises the proposed development as out of centre, but that it is in a location that will experience a very small increase in the residential population compared to other locations throughout Kingston. Furthermore, the Strategic Land Use Framework Plan identifies a proposed freeway that will run parallel to the eastern boundary of the Moorabbin Airport, next to the current industrial area. The industrial land and future freeway will provide a physical barrier between the proposed retail development and the nearest residential area, which is serviced by the Dingley Village Neighbourhood Activity Centre.


F IGURE 3. KINGSTON STR ATE GIC L AND USE PLAN

Source: Kingston Planning Scheme, Clause 21.04


Clause 21.05 Residential Land Uses AECOM did not consider this clause in their planning response in great detail, other than to state that:

“The Kingston Strategic Residential Land Use Framework Plan within the Kingston Planning Scheme signals incremental housing change for areas directly to the east and west of Moorabbin Airport. This indicates that there will be increased residential density and future population growth within the primary catchment of the proposed development.”

This comment is incorrect as discussed below. This clause highlights many factors that the planning response fails to adequately address. These include that:

Opportunities for significantly higher densities exist only within Kingston’s activity centres. The remaining opportunities for the development of large residential sites in Kingston are the

Waterways, The Heath and the Gas and Fuel Site (Nepean Highway). These locations are not located near the site of the proposed development (see Figure 4 below).

As outlined above, the closest residential area to the site, Dingley Village, is only nominated as an area for incremental housing change. The clause states the following in relation to areas of incremental change: “The type of housing change anticipated in these areas will take the form of extensions to existing houses, new single dwellings or the equivalent of new two dwelling developments on average sized lots. The existing single dwelling character of these areas is to be retained.”

Areas of minimal housing change will not play a big role in accommodating the growing population of Kingston. Future development in these areas is influenced by factors such as the Moorabbin Airport flight paths, single dwelling covenants and neighbourhood agreements.

A key issue and objective (Objective 5) of this clause relates to the management of interfaces between residential areas and other sensitive/strategic land uses. Strategies to achieve this objective include ensuring that the siting and design of new residential development does not encroach on strategic infrastructure or create potential conflict with established uses which have potential to erode residential amenity including the Moorabbin Airport and environs which are subject to aircraft noise. Furthermore, AECOM’s response to this clause does not consider existing zones and Moorabbin Airport environs that limit or prohibit development on land adjacent to, or surrounding, the site. Council’s population projections indicate that the closest residential area, Dingley Village, will only experience a population growth of approximately 600 people over the next two decades. This is a significantly smaller amount than is expected to occur in suburbs around activity centres within the municipality.


F IGURE 4. RE SIDE NTIAL LAND USE FRAMEWOR K PLAN



Clause 21.06 Retail and Commercial Land Use

AECOM

This clause identifies that the challenge over the next decade will be monitoring established retailing locations and restricted retailing precincts and that the implications of any retail activities at the Moorabbin Airport need to be closely monitored. New supermarket investment, particularly in the central and southern sections of the municipality, is encouraged to provide existing communities with greater choice and encourage higher utilisation of activity centres. Moorabbin Airport complements locally defined activity centres addressed by this Clause. The proposed development comprises a group of land uses that support and are complementary to the operation of the Airport and the broader urban setting and support the provision of balanced and necessary levels of service to the local community. The proposed development will bring substantial and direct benefits to the Airport community as well as the local and regional catchment in terms of improved services and amenities. As evidenced by the accompanying Economic Impact Assessment, the consequential impact of the proposed development on existing activity centres in this locality and region are within acceptable short and long term parameters and provides substantial economic benefit.

SGS

An objective of this clause is to protect and strengthen the hierarchy of activity centres within Kingston. Strategies to achieve this include consolidating new retail land use within the boundaries of existing activity centres. An objective is to reinforce the existing role of Southland PAC, complemented by the Cheltenham MAC, as the predominant regional focus for retail activity. The Moorabbin Airport is not identified in the Kingston Activity Centre hierarchy in 21.06-3. The clause also states that substantial expansion has occurred in Southlands PAC, Moorabbin Airport and new homemaker centres, including in Moorabbin. As a result the key challenge is to ensure the sustainability of Kingston’s established activity centres remain in line with the metropolitan strategy. While new supermarket investment is encouraged in the centre of the municipality to encourage higher utilisation of activity centres, as identified previously, the proposed development is not in a suitable location (at a distance from residential development, located adjacent to a green wedge, industrial zoned land as well as an airfield). The Clause specifically mentions that retailing activities at Moorabbin Airport need to be closely monitored. Objective 5 of the Clause aims to provide for the long term sustainability of Kingston’s restricted retail (bulky goods) precincts. Strategies to achieve this aim to reinforce the existing restricted retail precincts in Moorabbin, Cheltenham, Mentone, Parkdale and Heatherton, and to encourage consolidation of restricted retail precincts by preventing any new restricted retail development outside the existing precincts unless located in a designated activity centre. The Officeworks in the proposed development is a restricted retail premises and would require a permit if it were not on Commonwealth land. The Clause also recognises the importance of providing commercial office development within the municipality to responds to an increasingly educated local workforce. It states that the emergence of office precincts at the Moorabbin Airport and Parkview Estate reinforce a move towards campus style office precincts which differ from the historical suburban ‘in centre’ model.” To respond to the evolving nature of the commercial (office) market, a strategy in the Clause is to recognise the continual development of the establishing office precinct at Moorabbin Airport. The planning response incorrectly states the findings of the Retail and Commercial Development Strategy by stating:


“The Kingston Commercial and Retail Land Use Framework Plan with the Kingston Planning Scheme identifies Council’s preferred activity centre structure within Kingston. The Plan reflects the historic location of activity centres along the rail corridor and Nepean Highway, with only limited centres outside of this north-south transport spine. We note that the Framework Plan does not recognise the findings of the Council approved Retail / Commercial Development Strategy (City of Kingston with Charter Keck Cramer and Hansen Partnership, 2006) on which it is based.”

The Retail and Commercial Development Strategy actually suggests that:

“The development of a full-line supermarket on the corner of Centre Dandenong and Boundary Roads is also being considered. While is has been indicated that the Chifley Business Park workforce will provide significant support for such a supermarket, this is questionable given the shopping behaviour of typical households. It is more likely that the primary market for a supermarket in this location would be households within Dingley Village immediately to the east, and to a lesser degree, households immediately west of Moorabbin Airport. The impact of a new full-line supermarket at Moorabbin Airport on the Dingley Village Shopping Centre may be lessened by any endeavour of Woolworths to upgrade the existing Safeway supermarket in Dingley.”

The strategy then goes on to recommend that:

Council work proactively with Woolworths to explore upgrade opportunities for the Safeway in Dingley Village

The Kingston MSS should be modified to recognise the increased role non-aviation activities, specifically retail and commercial development, currently have, and will have in the future, at Moorabbin Airport.

The strategy’s observations and recommendations were therefore not accurately communicated in AECOM’s planning response. Clause 21.07 Industrial Land Use The planning response does not consider this clause. The clause highlights that the manufacturing sector has suffered in recent years; however, industries in Kingston are better placed than other areas to respond to restructuring. This is because the area has a diverse manufacturing base, high concentrations of industrial activity, central location to markets and a skilled labour force, and good access to transport and infrastructure. The clause states that potential future development of industry at Moorabbin Airport is likely to increase the availability of industrial land in the region. As there are limited industry/manufacturing locations left in Melbourne or Victoria, it is critical that the best possible use for this valuable land be realised. The clause includes strategies such as “promote the development of business incubators in the Moorabbin industrial area and in other locations where appropriate”. It highlights the planned ‘Garden Industrial’ estates directly to the east of the Moorabbin Airport in the existing industrial areas. The Kingston Industrial Land Use Framework Plan (see Figure 5 below) states that land and airspace at the Moorabbin Airport should be protected for aviation purposes and that surplus land should be developed as a high quality industry ‘business park’. There is no mention of retail.


F IGURE 5. KINGSTON IND USTR IAL LAND USE FRAMEWOR K PLAN



Clause 21.10 Non Urban Areas

AECOM

This clause seeks to sustain the operation and economic viability of the Airport by protecting airport operations and flight paths from intrusive/inappropriate land uses, and providing appropriate buffers around airport related activities to minimise their impact on surrounding land uses. This proposal is consistent with this clause as the development represents the implementation of a comprehensively planned development identified most recently in the Approved Master Plan. It is a non-core but complementary development to the operation of Moorabbin Airport.

SGS

The clause states that the future management of Kingston’s non urban areas is one of the largest challenges facing the City. It states that it is important that land use outcomes in the non urban area are not driven by short term economic expediency but seek to achieve sustainable use and development outcomes. A key issue identified by the clause is the protection of aircraft operations of the Moorabbin Airport from intrusion of inappropriate development. A strategy to achieve Objective 3 (relating to protecting economic and operational viability of key industries) is to protect Moorabbin Airport flight paths and their immediate environs from development or use which may compromise the long term viability of the airport or prejudice its safety and efficiency. Considering the importance placed on protecting airport operations, the proposed retail development is not appropriate. Clause 22.04 South East Non Urban Area Policy The planning response did not consider this clause. The policy applies to the Moorabbin Airport and aims to protect the economic and operational viability of key industries and infrastructure, including Moorabbin Airport. It also aims to ensure that use and development does not compromise metropolitan urban growth strategies. As stated above, as the economic and operational viability of the airport is the key consideration, the proposed retail development is not appropriate. Clause 22.05 Moorabbin Airport Environs

AECOM

This clause recognises significant role played by the Moorabbin Airport in the local and regional economy and in the state’s transport infrastructure. The proposed development complies with all noise abatement policies outlined in this clause.

Municipal Strategic Statement

AECOM

The proposed development is consistent with the municipal profile outlined in Clause 21.02. The Airport is clearly recognised as an important contributor to local, regional and State economies, and in achieving this, as a land use that elevates the regional significance of the City of Kingston.


The proposed development will bring substantial and direct benefits to the Airport community as well as the local and regional catchment in terms of improved services and amenities. As evidenced by the accompanying Economic Impact Assessment, the consequential impact of the proposed development on existing activity centres in this locality and region are within acceptable short and long term parameters. Also as discussed above, Moorabbin Airport is centrally located amongst existing and growing residential and industrial precincts. The Retail / Commercial Development Strategy (City of Kingston with Charter Keck Cramer and Hansen Partnership, 2006) recognises and supports the development potential of Moorabbin Airport and cited Moorabbin Airport as a location where future economic activity should be encouraged. As demonstrated by the Specialist Reports that accompany this proposal, the proposed development comprises a use that:

supports and is complementary to the operation of the Airport brings substantial and direct benefit to the Airport community, and the local and regional catchment

in terms of improves services and amenities

achieves this outcome with limited and reasonable impacts to the surrounding local or regional community, or existing activity centres in this locality and region

does not impact on airport operations and protects flight paths from intrusive/inappropriate land uses

complies with all noise abatement policies outlined in Clause 22.05.

SGS

The implications of these assertions have been discussed in the previous sections. To expand on this comment is made on the statement “Moorabbin Airport is centrally located amongst existing and growing residential and industrial precincts”. The fact of the matter is that the proposed retail outlets are remote from any residential development. There are no comparable situations in the metropolitan area.

Zones and Overlays

Zoning

SGS

As the Moorabbin Airport is on Commonwealth land, Victorian zoning is not applied to the land. However, it is worth considering any possible impacts of the proposed changes to Victoria’s zones. The proposed changes to the Victoria Planning Provisions standard zones are also likely to have implications for land use and employment. Broadly, the proposed zones are likely to see an all-round relaxation of zoning controls for retailing. A danger of this is that unintended ‘out of centre’ development may occur. Table 3 shows the proposed zoning reforms.


TAB LE 3. PRO PO SE D CHANG ES TO ZONE S

Delete nine existing zones Create five new zones Amend 12 existing zones

Residential 1 Zone Residential Growth Zone Low Density Residential Zone

Residential 2 Zone General Residential Zone Mixed Use Zone

Residential 3 Zone Neighbourhood Residential Zone Township Zone

Business 1 Zone Commercial 1 Zone Rural Living Zone

Business 2 Zone Commercial 2 Zone Green Wedge Zone

Business 3 Zone Green Wedge A Zone

Business 4 Zone Rural Conservation Zone

Business 5 Zone Farming Zone

Priority Development Zone Rural Activity Zone

Industrial 1 Zone

Industrial 2 Zone

Industrial 3 Zone

Source: DPCD, 2012

In terms of the impact on retailing, the proposed changes to zones would, if they proceed, have the following impacts:

Changes to Business 1, 2 and 5 zones to Commercial 1 zone: retail use will be as of right and floor space restrictions on retail use will be removed in the Business 2 Zone. It is not known whether any assessment of the likely outcome of these changes has been undertaken.

Changes to Business 3 and 4 zones to Commercial 2 zone: supermarkets up to 2,000 square metres will be as of right and can be adjoined by up to 500 square metres of additional shop use. This will reduce barriers to entry for rival/independent traders. Again, it is not known whether any assessment of the likely outcome of these changes has been undertaken.

These changes may pose a threat to the achievement of policies in the planning scheme that promote a clear hierarchy of activity centres. However, such changes should not be interpreted as suggesting a ‘free for all’ situation. As there are no business zones within the immediate surrounds of the Moorabbin Airport, the impact of the proposed zone changes is likely to be minimal. However, if the proposed zone changes are to proceed, there will be even greater opportunities to provide retail uses near residential populations. This creates an even more compelling reason for why careful thought needs to be given to what form of use the land in question is best put to.


F IGURE 6. PLANNING SCH E ME ZONE S

Source: Moorabbin Airport Master Plan 2010


2.3 Conclusion

AECOM

This technical report – Planning – has been prepared by AECOM to inform the preparation of a Major Development Plan (MDP) in accordance with the Airports Act 1996 by Moorabbin Airport Corporation (MAC). The purpose of this report is to assess the consistency of the proposal against the State and local planning framework. This MDP affects land in the north-east corner of Moorabbin Airport and is for the future retail use of this land by the Wesfarmers Group. As such, this project is known as the “Wesfarmers Group Project Major Development Plan” (the Wesfarmers Group Project). From this assessment, it is evident that the proposed Wesfarmers Group Project addresses and is consistent with the requirements of the Approved 2010 Airport Master Plan and all relevant State and Local planning considerations within the Kingston Planning Scheme. This assessment finds that the Project is a direct response to the directions set in the Approved 2010 Master Plan (and its predecessors) and is consistent with the objectives and the detailed performance criteria included in the approved Master Plan. Further, this assessment finds that the proposal meets the policy and performance criteria requirements of the Kingston Planning Scheme. This report, and the associated Social, Economic and Traffic Impact technical reports in particular demonstrate that the proposal is ideally located on this site, will not impact on the operational efficiencies of the Airport, and provides a number of direct economic and social benefits to the Airport and the surrounding and regional communities, while not undermining the existing hierarchy of activity

centres serving the region or impacting on amenity.

SGS

While the planning report has considered the most obvious information relating to airports in the federal, state and local policies, there has been little, and at times, no consideration given to other, equally important policies (including those relating to residential development), a limited/narrow interpretation of the policies and little regard to the significance of the site for aviation and employment land. The airport master plan, as well as State and local policy, recognise the Moorabbin Airport as a regionally significant and well established transport, industrial and commercial area. The airport is expected to further grow its aviation role in the future. The Aviation White Paper indicates that there has been more non-aviation development than aviation development in recent years on Australia’s federally leased airports. “The Government acknowledges that non-aviation development, and in particular retail development, has considerable potential for community impact because of the capacity of these developments to generate significant traffic flow and to impact on existing and planned off-airport retail development.” (p164) The major issue with the planning response is that the proposed retail development undermines the well developed policies in the planning scheme relating to the location of retail floorspace. The Moorabbin Airport is not an identified activity centre in SPPF or LPPF, nor is it identified in the retail hierarchy. The proposed development is therefore a major diversion from adopted policy. The MSS has been prepared in the context of State policy and it sets out the retail hierarchy in detail. A new centre of this size should only be countenanced in the context of a comprehensive review. This would require assessing the overall need for retail floor space and then deciding where it is best located.


The council has done a considerable amount of planning work to establish that all foreseeable retail needs can be adequately and feasibly accommodated within the policy framework. If additional retail floor space was required, deciding where it should be located would require the application of locational criteria, and, on this basis, retail floor space should be located where the population is and employment uses would be located with other employment uses. Any review of the Councils retail policies, if it were to identify a need for floor space expansion, would not recommend locating it in this location. Any consideration of appropriate planning criteria would confirm that the Moorabbin airport site, being so remote from housing, would be one of the last sites in the metropolitan area to be selected. It is concluded that the AECOM report is deficient insofar as it misapplies clear policies in the planning scheme, does not consider the appropriate criteria that would align with ‘orderly and proper planning’ and does not consider the opportunity cost of displacing more beneficial and policy aligned employment uses on the site. Hence the AECOM report has not established net community benefit and the review of all relevant considerations confirms that this important criterion is unlikely to be satisfied. [Type a quote from the document or the summary of an interesting point. You can position the text box anywhere in the document. Use the Text Box Tools tab to change the formatting of the pull quote text box.]

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