Amendment C151 –Ballarat Activity Centres Strategy
Formal Exhibition Submissions
Thematically categorised with Council officer responses
No.
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Brief Description
The submitter makes general criticism of the process and poor timelines
The submitter has no concerns.
The submitter supports the overall direction of the amendment and agrees with aligning the
Activity Centre network within the State Planning Policy Framework and the direction to
strengthen the Wendouree Major Activity Centre (MAC). The submitter has a number of concerns
about the nominated boundary of Wendouree MAC, the existing supply of retail floor space, and
the proposed net additional floor space.
4
The submitter highlights a number of issues in Buninyong, such as issues with zoning, public
transport problems, loss of character and a disconnect between Learmonth and Warrenheip
Streets.
5
The submitter supports the Strategy as an important planning tool for future retail development in
Ballarat. Supports the recommendations of three existing sites they currently operate in Ballarat.
The submitter requests the Strategy to include the Learmonth Street site as a Local Activity
Centre. Requests the Strategy to detail that Ballarat East requires a retail focus to cater for the
increasing retail development in the area and that the site at Victoria Street be designated as a
Local Activity Centre. Requests the Strategy to designate a Local Activity Centre on the corner of
Hertford and Tait Streets, Delacombe.
6
The submitter commends the Strategy in recognising the reclassification of the Harvey
Norman/Domain Living development and Stockland Wendouree Shopping Centre as part of a
wider Wendouree and Howitt Street Activity Centre than what was considered under the interim
report.
The submitter supports the recommendations of the report and intends to submit a request (for
their property located at 1318 Howitt Street, Wendouree) to rezone the land to Business 1 Zone
to accommodate the expansion.
7
The submitter supports Council in its endeavours to implement a municipality wide approach to
the delivery and promotion of Activity Centres. The submitter believes there should be an
extension of the Howitt Street activity/employment area adjacent to their site near the Selkirk
brick establishment.
8
The submitter supports some aspects of the Strategy; however it also has some significant
concerns – particularly in relation to the recommended future floorspace allocations for both the
Lucas and Delacombe town centres.
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10
The submitter appreciates receiving information about the amendment.
The submitter believes the current designation of retail and commercial floor space will limit
employment opportunities at Lucas and for Alfredton and surrounding areas.
The submitter believes that in order to ensure consistency across all Council strategies and plans,
that the Ballarat CBD Activity Centre boundaries as indicated in the Strategy be amended to
reflect those established in the Ballarat CBD Strategy (2010), so as to include all of the Railway
Station Precinct.
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No.
Specific requests for modifications to existing shopping centres
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The submitter has the following comments in relation to existing shopping centres
Northway Shopping Centre –
• The submitter supports the proposed extensions to current centre;
• Suggests extra car parking (angled) should be created within the road reserve of Doveton
Street North.
Pleasant Park Shopping Centre –
• The submitter believes that there should be provision of two additional car spaces in the
road reserve on the east side of Pleasant Street at the northern end of the existing car
parking strip.
• The submitter believes that there should be a car parking area created within the existing
City Oval reserve to provide additional parking for shopping centre use and use during
sporting activities.
Midvale Shopping Centre
• The submitter believes there should be a footpath constructed along the frontage of the
Midvale Shopping Centre in Geelong Road.
• The submitter believes there should be line-marking in the service road in front of 11541172 Geelong Road for car parking.
• The submitter believes the existing entry/exit point at Geelong Road should be widened
to allow for a dedicated left hand turn into Geelong Road.
Response:
It is acknowledged that the submitter has a number of requests in relation to Northway, Pleasant Park
and Midvale Shopping Centres. More specifically, the submitter believes that extra car parking should be
created at Northway Shopping Centre and Pleasant Park Shopping Centre. The request for extra car
parking is considered outside the scope of this amendment. Contact should be made with Council’s
Infrastructure Development Unit to discuss these modifications to the road reserve and within the
existing City Oval reserve.
The submitter also believes there should be some modifications to the accessibility of Midvale Shopping
Centre, such as construction of a footpath, line-marking in the service road and widening of the access
point to the centre from Geelong Road. This request is also outside the scope of this amendment and it
is suggested that a formal request is made in writing to the Infrastructure Development Unit.
No.
4
5
Specific requests for extensions of business and commercial zoned boundaries
• Buninyong - The submitter believes that instead of additional car parking on Learmonth
Street, Buninyong, the Business Zone should be amended to include the south side of Forest
Street.
• Midvale Shopping Centre - The submitter believes the commercial zoning should be extended
to the north side of Cartledge Avenue and west side of Geelong Road to southern boundary of
No. 1148 Geelong Road, Mt Clear.
Response:
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Buninyong – It is acknowledged the submitter believes that the existing Business Zone should be
amended to include the south side of Forest Street. However, the Strategy (p. 167) considered that an
expansion to the Buninyong Centre boundary was not warranted. Any such zoning change may impact
upon the residential amenity of the local community. Should a structure plan or urban design
framework be completed for the Centre, then further refinements to the boundary may occur subject to
further consultation.
Midvale Shopping Centre – It is acknowledged the submitter believes the commercial zoning should be
extended to the north side of Cartledge Avenue and west side of Geelong Road to southern boundary of
No. 1148 Geelong Road, Mt Clear. The Strategy recommends that the Activity Centre boundary of
Midvale is expanded to accommodate the anticipated need for additional floorspace as the centre
develops. An area to the north of the centre has been identified however there are also possibilities to
expand to the east across the highway. While the areas identified for inclusion in the centre on the
relevant Action Plan should be tested during a structure planning process, the Strategy’s
recommendations are intended to offer a starting point for that process.
The Strategy proposes to adjust the boundaries of two Activity Centres (namely Wendouree and Howitt
Street). The justification for the proposed changes is provided in the document (p. 175). It should be
noted however, that suggested changes to the boundaries should be tested and finalised through a
more detailed structure planning process. This is also true for other centres such as Sebastopol South
and Buninyong, despite no specific changes to their boundaries being identified in the Strategy.
No.
7
Specific changes to the Ballarat Activity Centre Strategy
• The submitter would like to modify the Strategy (p.17) to include the following points:
• Howitt Street east of the Midland Highway provides a logical extension to the existing
commercial/retail activities on the south side of Howitt Street
• The area includes a number of existing non residential uses
• The further investigation required should be undertaken as a matter of priority
• Council supports in principle the expansion of non residential uses in this area
• Expansion in this area should be promoted in the short to medium term.
Response:
The above comments in relation to the Ballarat Activity Centre Strategy are acknowledged. Changes to
the Strategy as advocated by the submitter are not supported as it would require the re-exhibition of
the amendment. Changes advocated shall be addressed as part of further investigations, subject to
business planning.
No.
10
Specific requests to make changes to the Local Policy Planning Framework
• The submitter wants the following Clauses of the LPPF to be amended:
•
Clause 21.04-1, amend the additional strategy 1.7 by addition of the words “Sustainable
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access will require suitable walking, cycling and public transport infrastructure in accordance
with the Department of Transport “Public Transport Guidelines for Land Use and
Development”, in order to facilitate the efficient rollout of bus services.
•
In Clause 21.04-4.1, amend the fifth dot point under Principal Activity Centres to “the
availability of multiple integrated public transport routes, which service and support the
Activity Centre and commercial development, as well as nearby medium density
development.”
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In Clause 21.04-4.2, amend strategy 1.17 to “Ensure the design and layout of centres
considers pedestrian and cyclist amenity, as well as the provision of infrastructure which will
facilitate the efficient provision and operation of public transport services.
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Clause 21.01 - The DOT Public Transport Guidelines for Land Use and Development (2008)
should be specifically referenced in Clause 21.10
•
Consideration should be given to referencing the DOT and VicRoads Advisory Note on
Integrated Transport Planning.
Response:
The above comments in relation to the Ballarat Activity Centre Strategy are acknowledged. Council
supports in principal the thrust of the submission and will refer them to the Panel for further
consideration.
No.
5
Specific requests to be included in Local Activity Centres
• The Submitter believes the Strategy needs to take into consideration reference to three (3)
additional sites that Council are aware of that potentially will be considered as Local Activity
Centres. The submitter provides information that the three sites (listed below) tick the factors
which designate a Local Activity Centre.
•
31-45 Learmonth Street, Alfredton – The submitter believes there has been an oversight
into the subject site being discussed in the Strategy. They believe that this site should be
included in the recommendations of the Strategy as defined as a ‘Local Activity Centre’ in
the Strategy.
•
200 Victoria Street, Ballarat East – The Ryan Group intends to develop a supermarket,
speciality stores and car parking at this site. They believe there is a need for a retail
presence in the Ballarat East area. The Ryan Group points out that the Strategy is silent
on Ballarat East and requests that the Strategy include this site as being a recognised Local
Activity Centre for the growing area of Ballarat East. Hence, the submitter requests the
Strategy to detail that Ballarat East requires a retail focus to cater for the increasing
residential development in the area and that the site at Victoria Street to be designated as
a Local Activity Centre.
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109 Hertford Street, Delacombe – The Ryan Group have designated the site for future
retail in the next 3 to 5 years and see that a supermarket on a local scale will provide the
retail need for existing residents and workers within the surrounding area. Therefore
requests the Strategy to designate a Local Activity Centre on the corner of Hertford and
Tait Streets, Delacombe.
Response:
The above comments in relation to the potential to add the following sites, 31-45 Learmonth Street,
Alfredton, 200 Victoria Street, Ballarat East, and 109 Hertford Street, Delacombe to the Local Activity
Centres are acknowledged. Although this submission has merit, it is considered that the best response in
to refer all submissions to an independent panel for consideration.
No.
3
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Concern for nominated boundary of Activity Centres and inclusion of Bulky Goods and Railway
Station Precincts
• The submitter is concerned about the nominated boundary of the Wendouree Major Activity
Centre. It notes the proposed exclusion of the bulky goods precinct and the railway station
from the Activity Centre and recommends that the Wendouree Activity Centre boundary
should include the adjacent bulky goods precinct and the Wendouree railway precinct.
•
The submitter believes that in order to ensure consistency across all Council strategies and
plans, that the Ballarat CBD Activity Centre boundaries as indicated in the Strategy be
amended to reflect those established in the Ballarat CBD Strategy (2010), so as to include the
entire Railway Station Precinct.
•
The submitter notes that the Wendouree Train Station and surrounding area is not included
within the Wendouree Major Activity Centre. The submitter believes that to ensure long term
desired land use and integrated transport outcomes for the Wendouree Train Station Precinct,
and to further improve pedestrian connectivity to and from the precinct and the Activity
Centre, it is suggested that these issues could be addressed via the development of a Precinct
Structure Plan.
Response:
It is acknowledged that two submitters are concerned about the nominated boundary of the
Wendouree MAC and that they believe the adjacent bulky goods precinct and the Wendouree railway
precinct should be included.
Bulky Goods Precinct
The Strategy highlights a number of sound planning reasons which underpin the recommended
amendments to the boundary of Wendouree Major Activity Centre (p. 175). The separation of the Bulky
Goods Precinct to the west of Gillies Street from the Wendouree Major Activity Centre is appropriate
given the different land uses and the clear distinction in design treatments and interaction with their
public realm. This area to the west of the Wendouree Major Activity Centre has been identified as a
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separate centre in recognition of the different types of activity and movement generated by a precinct
that specifically accommodates ‘bulky goods’ or large format retail stores.
Additionally, the Strategy supports Wendouree Bulky Goods precinct being further developed to
become a major bulky goods retailing destination in the City of Ballarat and wider region. However it is
important to carefully monitor and manage the types of retail uses which locate in this centre, to ensure
that it does not detrimentally impact on the role and function of the Ballarat CBD. Large format retail
uses to be encouraged within this precinct should be in keeping with State Policy definitions. Finally, it
should be noted that suggested changes to the boundaries should be tested and finalised through a
more detailed structure planning process.
Bulky goods retailing requires a different built form to traditional retail, particularly in relation to the
emphasis placed on vehicular access associated with larger products that may be purchased in these
stores. The Strategy (p. 153) seeks to recognise the different urban form that this is likely to entail.
While the preference is for all retail uses to be accommodated within designated Activity Centres as a
first priority, where this is not always possible, the Strategy has sought to ensure that these uses can be
provided in a single cluster. As there is an existing homemaker centre on the western edge of Gillies
Street North and a large area which has been rezoned by Ministerial Amendment to accommodate
further bulky goods uses, this is considered an appropriate location for such a cluster. It should be
noted that from one end of any combined Activity centre to the other would be over 2km by the arterial
road network.
This bulky goods precinct has been separated from the Wendouree Major Activity Centre as different
policy will apply to each of these areas. The bulky goods precinct does not reflect, nor can it be guided
by, State and local planning policy on Activity Centres, which seeks to achieve a mix of uses and place a
priority on pedestrian movement. Instead, development in this area should be guided by the Interim
Design Guidelines on Large Format Retail Premises.
Railway Station Precinct
It is acknowledged that two submitters are concerned that the Wendouree Railway Station and
surrounding area is not included within the Wendouree Major Activity Centre.
The commentary in the Strategy around transport and access provides the location of the railway
stations but makes no mention of them being included (or excluded for that matter) within the Activity
Centre boundary. For example, Ballarat Railway Station (p.49) is located in the north of the CBD on
Lydiard Street North and provides direct connections to Melbourne, Ararat and Maryborough. The
Wendouree Railway Station is also discussed in the Strategy providing its location and the buses which
service the Activity Centre.
It is acknowledged that in order to address the above outlined issues and further improve pedestrian
connectivity to and from the Wendouree Train Station Precinct and the Activity Centre, development of
a structure plan may be necessary. The Ballarat Activity Centres Strategy recommends the preparation
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of a structure plan to guide future development. This process will determine whether or not the
Wendouree Railway Station precinct is included in the Wendouree Major Activity Centre.
No.
3
Concern for existing retail and current floorspace
• The submitter believes the existing supply of retail floorspace within the City of Ballarat
referenced in the Strategy is overstated by approximately 100,000sqm.
• The submitter believes that the Strategy overstates the existing supply by approximately
100,000sqm (i.e. while the report indicates an overall supply of almost 348,600sqm (p.120),
the Deep End Services research suggests that the actual figure is closer to 255,000sqm).
• Essential Economics’ Retail Strategy prepared for the City of Ballarat in 2003 stated that the
total amount of floorspace provided in the municipality at that time was 207,870sqm, and it is
unrealistic to expect that this has now increased to almost 348,000sqm.
• The submitter believes the effect of such a discrepancy can be significant in terms of
forecasting additional floorspace requirements, and the timing for the supply/development of
new floor space.
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The submitter notes at “Table 1 to Clause 21.04-4 Activity Centre Hierarchy” that Alfredton
West is designated as “Proposed Neighbourhood Activity Centre – to develop into Large
Neighbourhood Activity Centre over time.” The submitter considers this designation limits the
potential for the NAC and adjoining commercial precinct to expand at Lucas (Alfredton West).
Under the retail strategy a Large Neighbourhood Activity Centre is defined as providing
generally between 10,000sqm and 20,000sqm of retail and commercial floor space. This
amount of floor space has already been provided for within the approved Alfredton West
Precinct Structure Plan for Lucas and the designation limits for potential for the Lucas Activity
Centre to expand and generate further employment and economic opportunities
The submitter believes the current designation of retail and commercial floor space will limit
employment opportunities at Lucas and for Alfredton and surrounding areas.
Response:
The above comments that the existing supply of retail floorspace provided in the Strategy may have
been overstated are acknowledged. However, Council officers have confidence that the consultants
engaged have provided accurate information on the existing supply of retail floorspace. The best way to
respond to this concern is to refer it to an independent Panel for further consideration.
No.
3
Concern for recommended future floorspace targets and timing
• In relation to Table 57 (p.151) of the Strategy – ‘Proposed Future Centre Hierarchy and
Growth Targets for the City of Ballarat to 2030’, while the submitter accepts that the
identified floorspace targets are indicative only (as stated on page 150), it is suggested that
this assessment may need to be revisited if the existing floorspace assessment in inaccurate.
•
The submitter states it is unclear what methodology has been used to determine the future
floorspace targets and the associated timing, and in particular those detailed in the Activity
Centre Action Plans for Wendouree.
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The submitter has some significant concerns – particularly in relation to the recommended
future floorspace allocations for both the Lucas and Delacombe town centres.
•
Lucas Town Centre - The submitter believes that the Activity Centre Strategy should be
updated to reflect the greater retail floor area that is proposed for the Lucas Town Centre.
Corresponding amendments should also then be made to Clause 21.04-4 to reflect the
amendments to the Strategy.
•
Delacombe Town Centre - The submitter considers that the Strategy should be updated to
reflect the floorspace and location of land uses that is now proposed for the Delacombe Town
centre. Draft Clause 21.04-4 should also then be updated to reflect these changes.
Response:
The above comments in relation to the identified allocation of future floor space are acknowledged. It is
important to note that these figures were originally devised to be indicative. In relation to the concern
for the recommended future floorspace allocations for Lucas and Delacombe town centres, Council
officers acknowledge that there may well be discrepancies between the floor space figures in the
Ballarat Activity Centres Strategy and the Ballarat West Precinct Structure Plan.
The Activity Centres Strategy was completed during the early stages of developing the Ballarat West
Precinct Structure Plan (PSP). The Ballarat West PSP now clarifies the activity centre hierarchy for
Ballarat West. The PSP is based on an economic assessment carried out by Macroplan (available to Hill
PDA at the time of developing their strategy). Council will submit to Panel the updates that would be
required to ensure the Activity Centre Strategy’s consistency with the more current PSP.
No.
Agency responses
2
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The Department of Sustainability and Environment has no concerns regarding the
amendment.
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• Louise Asher, Minister for Innovation, Services and Small Business and Minister for Tourism
and Major Events appreciates the letter and time taken to write and is thankful for receiving
the information regarding Amendment C151.
Response:
The comments are noted.
No.
General objection / comments
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Objects to the amendment
Questions the completeness of the document, stating that a large amount is missing
Believes that as the Strategy is dated September 2011 that it is out of date information
already
Believes that rezoning is not the answer to the rising number of vacant shops
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•
Questions the way the community received notice of the amendment, i.e not on official
letterhead, uses size 7 font and no official subject title.
Response:
The above submission is acknowledged. The Ballarat Activity Centres Strategy is a long term land use
plan. The Strategy provides clear and transparent policy recommendations to facilitate the short (2011 –
2016), medium (2017 – 2021) and longer term (2022 – 2030) planning of Ballarat’s centres so that they
meet the needs of a range of stakeholders. The Strategy does recommend some rezoning for Activity
Centres, however, these are kept to a minimum as the structure planning process will consider in more
detail any rezoning that is required in specific centres. There are some centres where rezoning may be
considered in the short term, as these are considered to have a strategic justification within the broader
context of planning within the City of Ballarat (p. 23).
No.
3
General support
• The submitter supports the overall direction of the Ballarat Activity Centres Strategy and
Amendment C151.
• More specifically, they agree with aligning the Activity Centre network within the SPPF and
the direction to strengthen the Wendouree Major Activity Centre (MAC).
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• The submitter supports the Ballarat Activity Centres Strategy as an overarching strategic
document and as an important Planning Tool for future retail development in Ballarat.
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• The submitter supports the recommendations of the report.
• The submitter commends the Strategy in recognising the reclassification of the Harvey
Norman/Domain Living development and Stockland Wendouree Shopping Centre as part of a
wider Wendouree and Howitt Street Activity Centre than what was considered under the
interim report.
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• The submitter supports Council in its endeavours to implement a municipality wide approach
to the delivery and promotion of Activity Centres.
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• The submitter supports some aspects of the Strategy
Response:
The above comments and general support are acknowledged. However following praise, many
submitters did then go on to list their concerns about varying aspects of the Strategy.
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