Bringelly Road Business Hub - Net Community Benefit & Sequential Test November 2014 - NSW Government
←
→
Page content transcription
If your browser does not render page correctly, please read the page content below
Bringelly Road Business Hub
Net Community Benefit & Sequential Test
November 2014
MacroPlan Dimasi MELBOURNE SYDNEY Level 4 Level 4 356 Collins Street 39 Martin Place Melbourne VIC 3000 Sydney NSW 2000 (03) 9600 0500 (02) 9221 5211 BRISBANE PERTH Level 15 Ground Floor 111 Eagle Street 12 St Georges Terrace Brisbane QLD 4000 Perth WA 6000 (07) 3221 8166 (08) 9225 7200 Prepared for: WSPT MacroPlan Dimasi staff responsible for this report: James Turnbull, Senior Manager – Retail Patricia Doherty, Senior Consultant - Planning
Table of contents
Executive summary ...................................................................................i
Introduction ............................................................................................. v
Section 1: Background ..............................................................................1
1.1 Proposed development and subject site context 1
1.2 Sequential test 5
1.3 Net Community Benefit Appraisal 6
Section 2: Sequential test ..........................................................................7
2.1 Precincts assessed 7
2.2 Crossroads – B5 zone 10
2.3 Hoxton Park – B5 zone 13
2.4 Leppington North Precinct – B5 zone 16
2.5 Orange Grove – B5 zone 19
2.6 Turner Road precinct – B5 21
Section 3: Site suitability analysis ............................................................. 25
3.1 Site suitability criteria 25
3.2 Site suitability assessment 26
Section 4: Review of Hill PDA Economic Impact Assessment ......................... 29
4.1 Hill PDA Review 29
4.2 Other comments 31
Section 5: Net community benefit test ...................................................... 35
This page has been intentionally left blank.
Executive summary
This report presents a sequential test analysis and net community benefit test of
the proposed development being considered at the Bringelly Road Business Hub,
located within the Western Sydney Parklands (WSP), in the Liverpool local
government area (LGA). This report also includes a strategic economic analysis,
including a review of the Hill PDA Economic Impact Assessment (EIA) prepared for
the proposed development in November 2014. The following key points
summarise our analysis:
Sequential Test
We have assessed all of the existing B5 zoned precincts across the Liverpool
LGA, and the B5 zoned precinct at Turner Road in the Camden LGA, for sites
that could accommodate the proposed development concept being considered
by Western Sydney Parklands Trust (WPST) (i.e. a site of around 20 ha).
We note that the development concept includes provision of up to 50,000 sq.m
of large format retail (LFR), with the remainder to consist of ancillary uses and
light industrial uses. We note that the LFR component is proposed to cover an
area of about 12 – 13 ha however we have examined potential sites of around
20 ha as the development scheme will provide additional economic benefits as
a whole, rather than as a segregated development scheme.
In summary, there is virtually no supply available in any of the three B5 zoned
precincts in the Liverpool LGA (i.e. Hoxton Park, Orange Grove and
Crossroads).
The proposed B5 precincts in the Leppington North precinct are incongruous,
too small and fragmented in terms of ownership. We do not consider that any
of the proposed B5 parcels identified within the Leppington North precinct
could accommodate the proposed development concept due to the constraints
associated with each of them, in particular fragmentation of land ownership.
Bringelly Road Business Hub
i
Net Community Benefit & Sequential Test
Executive summary
The Turner Road precinct is a significant distance (i.e. about 15km) from the
Bringelly Road subject site and is not considered to be a practical alternative
site to accommodate the proposed development. In any regard, the Hill PDA
EIA report indicates that a significant market gap will exist for LFR/bulky goods
retail by 2026 even assuming the Turner Road precinct is completely
developed.
Site suitability
We consider that the Bringelly Road subject site is a suitable site to
accommodate the proposed development as it is located within an identified
strategic centre (i.e. a Business Hub) in the WSPT Plan of Management 2020,
and the proposed uses are permissible with consent according to the State
Environmental Planning Policy (Western Sydney Parklands) 2009 (SEPP).
The subject site meets the requirements of the Site Suitability Criteria in the
Draft Centres Policy - Planning for Retail and Commercial Development which
was released in 2009 by the Department of Planning, as it was at the time
(Draft Centres Policy). It is presently serviced by several bus routes; will have
sufficient pedestrian and bike access; has excellent local and regional road
access being located at the confluence of Cowpasture Road, Bringelly Road and
Camden Valley Way, the latter of which is a key access route through the
region; is proximate to a current and future labour market and does not impact
the supply of housing or industrial land in the region (indeed it improves the
industrial land stock). New, modern development will also improve the amenity
of the location, providing a gateway development to the South Western Growth
Centre (SWGC) and the WSP.
Strategic Economic Justification
The retail sector is dynamic and evolves very rapidly. Therefore, future
planning for retail should be cognisant of new retail tenants and new retail
formats that might appear. Sites that offer flexible floorplates, excellent
accessibility and indeed a point of difference from a traditional centre, should
be encouraged and supported.
Bringelly Road Business Hub
ii
Net Community Benefit & Sequential Test
Executive summary
Hill PDA’s analysis has shown a significant market gap will exist for LFR/bulky
goods floorspace in the trade area by 2016 and that this gap will grow
significantly in the future. Hill PDA note that the south-west region will be
27,000 sq.m under-supplied in LFR floorspace by 2016, and around 75,000
sq.m under-supplied by 2026, even assuming the Turner Road precinct is fully
developed.
We consider that Hill PDA may slightly underestimate the overall demand for
bulky goods/LFR floorspace across the south-west region. Although even
based on Hill PDA’s numbers, we agree that there is currently considerable
bulky goods/LFR demand generated by the population in the south-west
region.
Based on Hill PDA’s numbers, we calculate the proposed development at the
subject site will only absorb about 3 – 3.5 years’ worth of future bulky
goods/LFR demand generated by the surrounding population.
We broadly agree with the analysis of trading impacts in the Hill PDA report, in
that impacts are likely to be distributed widely, across a range of
centres/precincts in the region. The Hill PDA analysis of economic impacts on
the surrounding centres network demonstrates that the proposed staging of
the project will serve to reduce any potential adverse trading impacts on
surrounding centres across the region.
Furthermore, because there is such significant market growth expected in the
region, all centres/precincts stand to benefit from this growth, and even with
the Bringelly Road development, trading levels across most identified centres
will be more than 20% above current trading levels (in constant dollar terms)
by 2020.
We agree that the potential impacts that will be experienced by traditional
retail facilities and proposed traditional business centres such as the
Leppington Major Centre and Edmondson Park Town Centre will be negligible.
We agree that the B5 zoned land in the Leppington North precinct is
constrained in that it is fragmented in ownership and lacks congruity. These
factors inhibit potential development considerably.
Bringelly Road Business Hub
iii
Net Community Benefit & Sequential Test
Executive summary
We note that Hill PDA has only considered the employment impacts associated
with the proposed LFR component of the development. Additional employment
will be supported as part of the supporting ancillary and light industrial uses,
both on site and during the construction phase of the project.
Net Community Benefit Test
The proposed development on the site could potentially result in a range of net
community benefits, particularly when compared against a base case scenario, of
no development. Some of the more important benefits are listed below:
Provide reasonable commercial returns necessary for WSPT to self-fund the
future upkeep of the WSP, which has very broad reaching community benefits.
WSPT is a self-funding agency.
The proposed development will help to fund improvements in the WSP in the
Liverpool LGA, including major regional recreation facilities, bike and walking
tracks, tourism and sports facilities and the upgrade and maintenance of major
environmental and wildlife corridors.
Increased convenience and amenity for the population in the region.
Ensuring sufficient LFR/bulky goods floorspace is made available to meet local
and sub-regional demand, particularly demand generated by the expected
future population in the SWGC.
Ensuring the right type of uses are provided in the right location at the right
time to meet the needs of the consumer.
A contribution to local employment and consequent economic multiplier
impacts.
A reduction in vehicle kilometres travelled as people are able to conveniently
shop and work in closer proximity to their place of residence in the SWGC.
If the proposal does not proceed in its current form, the above benefits will not be
realised.
Bringelly Road Business Hub
iv
Net Community Benefit & Sequential Test
Introduction
This report presents a sequential test analysis and net community benefit
appraisal of a proposed development being considered at the Bringelly Road
Business Hub, located within the Western Sydney Parklands (WSP), in the
Liverpool local government area (LGA). This report also includes a strategic
economic analysis, including a review of the Hill PDA Retail Demand and Economic
Impact Assessment (EIA) prepared in October 2014.
This report has been prepared under instruction from the Western Sydney
Parklands Trust (WSPT), and considers anticipated net community benefits that
will result from the proposed development concept in accordance with the NSW
Department of Planning and Environment (DPE) draft Centres Policy 2009;
whether there are any appropriately zoned, practical alternative site opportunities
that exist at in-centre or at edge-of-centre locations in the Liverpool LGA and
surrounding LGAs, that could accommodate the proposed development concept;
and includes a strategic economic analysis that considers the Hill PDA EIA.
This report is to be read in conjunction with the development application that is
being submitted for the proposed development, prepared by JBA Planning.
This report is structured as follows:
Section 1 – Background: provides a background to the report, including a
brief overview of the development concept being considered by WSPT and
provides an overview of the sequential test and net community benefit tests,
as outlined in the Draft Centres Policy.
Section 2 – Sequential Test: examines all of the existing B5 zoned precincts
across the Liverpool local government areas (LGA), and the B5 zoned precinct
at Turner Road in the Camden LGA, for sites that could potentially
accommodate the proposed development concept. This process is referred to
as the ‘sequential test’ and this section assesses all sites within these centres
as well as edge-of-centre locations around these centres.
Bringelly Road Business Hub
v
Net Community Benefit & Sequential Test
Introduction
Section 3 – Site Suitability Assessment: provides an assessment of the site
suitability criteria for out-of-centre commercial development, as outlined in the
NSW DPE draft Centres Policy 2009, in order to determine whether the subject
site is suitable for such development.
Section 4 – Strategic Economic Analysis: provides a review of the Hill PDA
EIA which has been prepared as part of the development application for the
proposed development, and highlights other key economic issues of relevance
to the proposed development.
Section 5 – Net Community Benefit Assessment: examines the net
community benefits associated with the proposed development were it allowed
to be provided at the subject site. This assessment examines the proposal
against a base case, addressing the evaluation criteria of the Draft Centres
Policy net community benefit test.
Bringelly Road Business Hub
vi
Net Community Benefit & Sequential TestSection 1: Background
This section of the report provides a background to the analysis, including a brief
overview of the development concept being considered by WSPT and provides an
overview of the sequential test and net community benefit tests, as outlined in
the Draft Centres Policy.
1.1 Proposed development and subject site context
WPST is proposing to develop the Bringelly Road Business Hub for large format
retail (LFR), light industrial and ancillary supporting uses. (Refer to Map 1.1 and
1.2).
The subject site is located on Bringelly Road, Horningsea Park in the Western
Sydney Parklands (WSP), at the confluence of Camden Valley Way and
Cowpasture Road. The proposed development plans are present as Figure 1.1 and
show that the subject site incorporates an area of 208,605 sq.m
(i.e. 20.8 hectares (ha)).
The proposed development that is being considered includes a mix of LFR, light
industrial (i.e. industrial units/warehouses) and ancillary uses. The development
plans indicate provision of up to 50,000 sq.m of LFR floorspace as well as
approximately 40,000 sq.m of ancillary and light industrial, employment
generating uses. The types of tenancies that would be considered as LFR include
the likes of Masters, Bunnings, Mitre 10 IKEA, furniture retailers, large pet stores
(e.g. Pet Barn) and the like. Such uses would not tend to form part of a traditional
retail centre, due to the large floorplates of such tenants.
The proposed LFR component of the development is likely to be staged, with
approximately 30,000 sq.m of LFR to be developed by 2016/17 and the remaining
20,000 sq.m of LFR to be developed around 2018/19.
Bringelly Road Business Hub
1
Net Community Benefit & Sequential TestFigure 1.1
Section 1: Background
1.2 Sequential test
The Draft Centres Policy details a “Sequential Assessment Test” which is to be
applied to rezoning proposals for out-of-centre commercial development.
However, the Bringelly Road subject site forms part of an identified ‘Business Hub’
in the overarching strategic document for the WSP, namely the approved WSPT
Plan of Management 2020 (supplement approved in 2014). Furthermore, all of the
uses being considered as part of the proposed development concept are
permissible uses with consent pursuant to the SEPP.
In that context, we consider the subject site to be ‘in-centre’ and arguably should
not be subject to a sequential test analysis. However, we have prepared a
sequential test analysis as this has been requested by WSPT.
The proposed development concept being considered proposes the development
of around 90,000 sq.m of GFA across the whole site. Having regard to appropriate
set-backs, ingress/egress, car-parking, and other factors such as circulation,
loading and unloading, the overall area required to practically support such a
development concept is in the order of 20 ha. We have therefore investigated the
potential for sites around 20 ha.
The sequential test requires proponents to assess the potential for available in-
centre or edge-of-centre sites and to demonstrate reasons as to why alternative
site options cannot be pursued, if they exist, before consideration is given to an
out-of-centre location. The steps involved are:
Step 1 - Firstly, it must first be demonstrated that there are no suitable sites
within an existing or planned new activity centre that can accommodate the
demand by adjusting future intentions, which could include:
- Increasing height and floor space controls,
- Permitting a broader mix of uses, or
- Actions to facilitate site availability or site consolidation.
Bringelly Road Business Hub
5
Net Community Benefit & Sequential TestSection 1: Background
Step 2 - Secondly, it must then be demonstrated that there are no suitable
sites in an edge-of-centre location that can satisfy the demand to be
accommodated.
Step 3 - Thirdly, an out-of-activity centre site that can satisfy the demand to
be accommodated may be considered if it meets the Site Suitability Criteria
and is consistent with relevant local or regional planning strategy.
Section 2 of this report address the Sequential Assessment Test and Section 3
assesses the subject site against the Site Suitability Criteria.
We have examined all B5 zoned precincts in the Liverpool LGA, and the Turner
Road precinct in the Camden LGA, in order to identify potential sites that could
accommodate the proposed development concept being considered by the WSPT.
We have also examined future B5 zoned precincts, as well as edge-of-precinct
locations.
1.3 Net Community Benefit Appraisal
The NSW DPE draft Centres Policy 2009 provides a guide for the assessment of
planning proposals for ‘out-of-centre’ developments. The draft Centres Policy
recognises the usefulness of a net community benefit appraisal to inform the
decision making process of the planning authority”... where it is judged that the
rezoning would produce a net community benefit, the proposal should proceed
....” (p.26, draft centres policy, April 2009).
As stipulated in the draft Centres Policy, a “net community benefit (NCB) test”
should consider the external costs and benefits of a proposal, such as net welfare
effects or the net impact on other centres, as opposed to possible private costs
and benefits.
The NCB test should also allow for the consideration of a proposal against a base
case, such as the development not proceeding. The NSW DPE’s draft Centres
Policy also provides a series of evaluation questions to assist the NCB analysis.
Section 5 of this report sets out a net community benefit assessment against all
of the criteria on p.25 and p.26 of the draft Centres Policy.
Bringelly Road Business Hub
6
Net Community Benefit & Sequential TestSection 2: Sequential test
This section of the report examines all of the existing B5 zoned precincts across
the Liverpool local government areas (LGA), and the B5 zoned precinct at Turner
Road in the Camden LGA, for sites that could potentially accommodate the
proposed development concept. This process is referred to as the ‘sequential test’
and this section assesses all sites within these centres as well as edge-of-centre
locations around these centres.
For the each selected centre in this section we have assessed site areas, lot
configuration (i.e. ownership, depth, road networks, and loading requirements),
land use conflicts, existing uses, and proposed uses.
We have examined the various precincts in order to identify potential sites that
could accommodate the proposed development concept being considered by
WPST (i.e. a site of around 20 ha). We note that the development concept
includes provision of up to 50,000 sq.m of large format retail, with the remainder
to consist of ancillary uses and light industrial uses. We note that the LFR
component covers an area of about 12 – 13 ha, however we have examined
potential sites of around 20 ha as the development scheme will provide additional
economic benefits as a whole, rather than as a segregated development scheme.
2.1 Precincts assessed
The first step of the sequential test is to examine all of the appropriately zoned
land within the locality of the subject site to determine whether there are any
suitable sites to accommodate the proposed development.
The proposed development consists of LFR, light industrial and ancillary uses, for
which the B5 – Business Development zone would be the appropriate equivalent
zone. Particular regard has been given to sites that are reasonably closely located
to the Bringelly Road subject site, although we have investigated all sites in the
Liverpool LGA as well as Turner Road in the Camden LGA.
Bringelly Road Business Hub
7
Net Community Benefit & Sequential TestSection 2: Sequential test
To avoid repetition, we have also examined the edge-of-centre locations at each
of these centres in the same sub-section. The ‘centres’ we have examined for
potential opportunities, including both ‘in-centre’ and ‘edge-of-centre’ locations,
are shown in Map 2.1 and listed below:
1. Crossroads – B5 zoned land (including Costco)
2. Hoxton Park – B5 zoned land (including Masters Home Improvement)
3. Leppington North Precinct – B5 zoned land (future centre/precinct)
4. Orange Grove – B5 zoned land (Liverpool Markets and Megacenta Liverpool)
5. Turner Road – B5 zoned land (includes Masters Home Improvement store)
Bringelly Road Business Hub
8
Net Community Benefit & Sequential TestSection 2: Sequential test
2.2 Crossroads – B5 zone
The Crossroads B5 precinct includes the area bounded by Camden Valley Way,
the Hume Highway/M5 and Campbelltown Road (Refer Figure 2.1 and Map 2.2).
The precinct includes a B5 zoned area of 277,800 sq.m (i.e. 27.8 ha), generally
provided over six large lots. The Crossroads Homemaker Centre and Costco Retail
Warehouse occupy all of the available developable land within this B5 precinct.
The Crossroads Homemaker Centre occupies three blocks around the intersection
of Beech Road and Parkers Farm Place with frontage to Camden Valley Way. The
Costco Retail Warehouse (13,500 GFA) occupies the remaining south-west part of
the B5 precinct. There is no vacant land available within this B5 zoned precinct.
The precinct is a popular and functional homemaker and regionally oriented bulk
grocery shopping destination.
To the north and east of the precinct are residential zoned areas that would be
impractical for rezoning to accommodate the proposed development as this would
most certainly result in a net community disbenefit. A change of zoning from
residential to a lower order business zone constitutes a very significant adverse
outcome for the local community. To the west, is the western edge of the
Edmondson Park precinct, which is expected to accommodate future residential
and small scale neighbourhood retail/commercial uses and recreational zoned
land.
There is a strip of B6 – Enterprise Corridor land along Camden Valley Way. The
B6 zone does not permit bulky goods retail tenancies greater than 2,500 sq.m.
Additionally, this strip of B6 land is too narrow to accommodate the floorplates
proposed for the prospective LFR tenancies at the Bringelly Road site.
The large industrial precinct south of the Crossroads B5 precinct covers an area of
21 ha of IN3 – Heavy Industrial zoned land. The objectives for this precinct are to
support heavy industrial uses that may not be ideal in the light industrial and
general industrial zone. While this precinct allows warehouse and distribution
centres, retail and bulky goods uses are not permissible in this zone.
Bringelly Road Business Hub
10
Net Community Benefit & Sequential TestSection 2: Sequential test
This IN3 precinct is current vacant and could potentially be considered for
rezoning to B5. The precinct is of sufficient scale to support the proposed
development scheme. However an industrial development application has been
approved for this site and this precinct is considered to be strategically important
industrial land precinct according to the NSW DPE draft South-West Sub-Regional
Strategy and therefore does not present an appropriate site for rezoning.
Furthermore, this would require the purchase and consolidation of several lots
from private land owners and Council and NSW DPE supporting a planning
proposal to rezone the site. This option is undesirable as these factors are outside
the control of the WSPT and would require the support of many parties.
In summary, the Crossroads B5 precinct cannot accommodate the proposed
development concept being considered at the Bringelly Road subject site as there
is no vacant land available – and the existing uses are fully operational and serve
an important community service providing homemaker and bulk grocery shopping
destination.
Figure 2.1 – Crossroads B5 precinct
Bringelly Road Business Hub
11
Net Community Benefit & Sequential TestSection 2: Sequential test
2.3 Hoxton Park – B5 zone
The Hoxton Park B5 zoned precinct includes the 34,700 sq.m (3.47 ha) area at
the northern intersection of Cowpasture Road, Airfield Drive and the Westlink M7.
The precinct is currently fully occupied by a 13,680 sq.m (GFA) Masters Home
Improvement Store, with at-grade car parking. (Refer Figure 2.2 and Map 2.3).
There is no vacant space within this B5 zoned precinct.
To the north of the subject site is a 36.8 ha precinct of IN1 – General industrial
land which is almost completely occupied by two significant distribution centres,
both leased to Woolworths Ltd and owned by Mirvac. There is a small (2.9 ha)
unoccupied parcel of IN1 zoned land between these distribution centres and the
Masters Home Improvement Store, but this site is too small to support the
proposed development being considered at the Bringelly Road subject site.
The Hoxton Park B5 precinct is generally surrounded by public recreation zoned
land and residential zoned land in most directions, and these areas would not be
suitable to be redeveloped for LFR and light industrial uses. There is a vacant 4 ha
parcel of land south of Cowpasture Road that is zoned B6 – Enterprise Corridor.
As previously identified the B6 zone does not allow bulky goods retail tenancies
greater than 2,500 sq.m, with some exceptions for certain tenant types, however,
this precinct would be too small to accommodate the proposed development being
considered at Bringelly Road.
In summary, the Hoxton Park B5 precinct could not accommodate the proposed
development being considered at the Bringelly Road subject site as there are no
vacant parcels available.
The B6 land situated directly south of Cowpasture Road could potentially be
considered for rezoning to B5, however under such a zoning, the site would still
be too small to support the proposed development scheme in terms of
supportable area, for a development scheme that requires about 20 ha of land.
Furthermore, this would require the land owners wanting to sell their land and
Council and NSW DPE supporting a planning proposal to rezone the site, none of
these factors which are the control of the WSPT.
Bringelly Road Business Hub
13
Net Community Benefit & Sequential TestSection 2: Sequential test
Figure 2.2 – Hoxton Park B5 precinct
Bringelly Road Business Hub
14
Net Community Benefit & Sequential TestSection 2: Sequential test
2.4 Leppington North Precinct – B5 zone
The Austral and Leppington North precincts have now been zoned for urban
development by the NSW DPE. According to the most recent Indicative Layout
Plan (ILP), the Leppington North precinct is ear-marked to provide around 30 ha
of B5 zoned land, distributed across four fragmented precincts (Refer Figure 2.3
and Map 2.4).
The two southern zoned parcels of land around Cowpasture Road cumulatively
total about 5.3 ha. These parcels are clearly not suitable for the proposed
development concept being considered at the Bringelly Road subject site as they
are individually, and indeed, collectively too small.
The two northern parcels totally 24.9 ha (9.6 ha and 15.2 ha), located along
Bringelly Road are incongruous, separated by an area designated as future public
recreation land, and thus could not support the proposed consolidated
development concept being considered at the Bringelly Road Business Hub.
Further compounding this physical disconnect, is the issue of fragmentation of
land ownership. Not only are there existing uses on these parcels, but there are
17 individual lots within these precincts. These lots would need to be purchased,
consolidated and existing buildings demolished in order to provide a large
development.
We consider these identified practical constraints that would severely impact the
feasibility of large consolidated development schemes in this location. Such
projects would have a high level of risk and longer development timeframes than
a similar project that could be developed at Bringelly Road, which could provide
jobs and services in the short-term for the surrounding population, as there are
minimal encumbrances at the subject site.
In summary, we do not consider that any of the proposed B5 parcels identified
within the Leppington North precinct could accommodate the proposed
development concept due to the size of each parcel and the constraints associated
with each of them.
Bringelly Road Business Hub
16
Net Community Benefit & Sequential TestSection 2: Sequential test
Figure 2.3 – Leppington North Major Centre
Bringelly Road Business Hub
17
Net Community Benefit & Sequential TestSection 2: Sequential test
2.5 Orange Grove – B5 zone
The Orange Grove B5 zoned precinct covers an area of 170,200 sq.m
(i.e. 17.0 ha) at Orange Grove Road, in Liverpool. The northern part of the
precinct is occupied by the Liverpool Megacenta and the southern part of the
precinct is occupied by the Liverpool Markets. There is a vacant area of 3.5 ha
near the Megacenta and a vacant area of about 1 ha to the east of the
Liverpool Markets, both areas which would be too small to accommodate the
proposed development being considered at Bringelly Road.
The frontage to Orange Grove Road is zoned B6, which presently accommodates a
Dan Murphy’s, and several fast food developments, however, this site is too small
for the proposed development.
The B5 precinct is surrounded by residential and recreational zoned land in most
directions, and a large IN1 – General industrial precinct to the south of about
21.5 ha. The industrial estate is almost completely occupied with 2 – 3 small,
incongruent, vacant spaces within the precinct.
This industrial precinct could potentially be considered for rezoning, although the
significant costs associated with demolishing existing buildings and amalgamating
lots means that this would be a highly impractical pathway and would not result in
any benefit to the community, and may indeed result in a disbenefit
Figure 2.4 – Orange Grove precinct
Bringelly Road Business Hub
19
Net Community Benefit & Sequential TestSection 2: Sequential test
2.6 Turner Road precinct – B5
The Turner Road B5 zoned precinct, located in the Camden LGA, is the primary
location for future bulky goods/LFR in the southern part of the SWGC. The
58.3 ha precinct (Refer Figure 2.5 and Map 2.6) is located about 15 km south of
the Bringelly Road subject site and we do not consider it to be a practical
alternative to the proposed Bringelly Road subject site given it is so far away. The
Turner Road precinct will service the southern parts of the SWGC, and the areas
further south around Narellan, Camden and Campbelltown, while the
Bringelly Road site will also service these areas but in particular, the northern part
of the SWGC and the Liverpool and Fairfield LGAs.
The Turner Road B5 precinct is controlled by two land owners, both looking to
actively develop their land. Gregory Hills Corporate Park owns the land to the
north of Turner Road and Dart West owns the land to the south. The southern
parcel of land currently accommodates a Masters Home Improvement Store,
south of Turner Road and The Central Hills Business Park, which has development
approval to support a new multi-tenant bulky goods retail development of about
30,000 sq.m. We expect future developments to occur in Gregory Hills Corporate
Park over the next few years, as these land owners are actively looking to develop
that site, some uses may not be retail.
We consider there to be an important role for the Turner Road precinct to
accommodate future bulky goods/LFR development as well as a range of other
uses permitted in the B5 zone, in addition to the Bringelly Road Business Hub.
There is a significant volume of LFR/bulky goods floorspace demand expected
across south-west region over the next 20 – 30 years. The Hill PDA EIA report,
which is reviewed in Section 4 of this report indicates that a significant market
gap will exist for LFR/bulky goods retail by 2026 even assuming the Turner Road
precinct is completely developed.
Bringelly Road Business Hub
21
Net Community Benefit & Sequential TestSection 2: Sequential test
Figure 2.5 – Turner Road B5 zone
Bringelly Road Business Hub
22
Net Community Benefit & Sequential TestThis page has been intentionally left blank.
Section 3: Site suitability analysis
This section of the report provides an assessment of the site suitability criteria for
out-of-centre commercial development, as outlined in the Draft Centres Policy, in
order to determine whether the subject site is suitable for such development.
The sequential test states that if no alternative site locations ‘in-centre’ or ‘edge-
of-centre’ are deemed suitable for a proposed development, then any out of
centre proposal should examine the suitability of the proposed site for its intended
use.
We consider the Bringelly Road subject site to be a suitable site to accommodate
the proposed development as it is defined as a strategic centre (i.e. a Business
Hub) in the WSPT Plan of Management 2020, and the proposed uses are
permissible with consent pursuant to the SEPP.
3.1 Site suitability criteria
The following site suitability criteria are recommended on page 11 and page 12 of
the draft Centres Policy to be used when assessing the suitability of a prospective
out-of-centre site, noting that these criteria are much more applicable to
traditional centres (i.e. B1, B2 B3), rather than B5 land, as LFR retail tends to be
accessed by car-based transport:
Access to public transport, or the infrastructure capacity to support future
public transport.
Good pedestrian access.
Good road access for employees, customers and suppliers and, where
necessary, capacity to provide new road infrastructure.
Close proximity to local labour markets with the skills required by business.
Prestons Rezoning Proposal
25
Sequential testSection 3: Site suitability analysis
Urban design opportunities that create the potential to integrate with
surrounding land uses.
Potential to increase the amenity of the local area.
3.2 Site suitability assessment
The subject site at Bringelly Road performs as follows against the criteria specified
in Sub-section 3.1:
The subject site is serviced by public buses, and is close to the South West Rail
Link, which extends to the Leppington Major Centre, 2 - 3 km to the west of
the site, with services expected to be operational by 2015.
The subject site has sufficient pedestrian and bike access. Any additional
linkages required to the site can be provided at the time of the stage 1
development application.
The subject site is located at the confluence of Cowpasture Road, Bringelly
Road and Camden Valley Way, the latter of which is the main vehicular access
route through the region, linking to the Hume Highway to the north and to
Camden in the south, affording excellent access for prospective employees,
customers and suppliers.
The subject site, being situated in an area that is predominantly residential,
with strong population growth, is therefore proximate to an existing labour
market and growing potential future labour market.
The proposed development of the subject site for LFR, light industrial and
ancillary uses, will not impact the supply of housing, as residential
development is not allowed at the subject site, according to the SEPP. The
proposed development includes some light industrial uses however the subject
site is a stand-alone site, with a very broad range of permissible uses and is
not part of a key industrial precinct in the Liverpool LGA. Furthermore, the
subject site could be redeveloped for a variety of non-industrial uses under the
Bringelly Road Business Hub
26
Net Community Benefit & Sequential TestSection 3: Site suitability analysis
SEPP. If anything, the proposed development will add to industrial stock in the
region without reducing industrial land supply.
The urban design elements of the proposal can be further negotiated at the
time of stage 1 development application.
A new modern LFR development concept, with supporting light industrial and
ancillary uses, which meets relevant urban design standards, would, in our
view, improve the visual amenity of the local area.
In regards to whether the site will contribute to environmental outcomes and
have regard for environmental issues, the proponents have undertaken the
necessary technical assessments examining various constraints and would be
willing to discuss and address any issues with Council and/or the NSW DPE.
This assessment shows that the Bringelly Road Business Hub site would perform
very well against the suggested site suitability criteria in the Draft Centres Policy
and the proposed development being considered for the site is considered to be
appropriate for the site in the above context.
Bringelly Road Business Hub
27
Net Community Benefit & Sequential TestThis page has been intentionally left blank.
Section 4: Review of Hill PDA Economi c Impact
Assessment
This section of the report provides a review of the Hill PDA EIA which has been
prepared as part of the development application for the proposed development,
and highlights other key economic issues of relevance to the proposed
development.
As part of the suite of technical reports prepared for the development application
for the proposed development, Hill PDA prepared a report titled, “Bringelly Road
Business Hub – Retail Demand and Economic Impact Assessment” in
November 2014, on behalf of the WSPT.
4.1 Hill PDA Review
We generally support the key findings of the Hill PDA report and make the
following points in relation to the report:
Hill PDA has examined the demand and supply of LFR and bulky goods retail
floorspace within the trade area which was defined to include the south-west
sub-region (i.e. the LGAs of Liverpool, Camden, Wollondilly and
Campbelltown).
We consider that the trade area under consideration is conservative, and could
indeed stretch further to include areas within the Fairfield LGA, particularly if
large, unique LFR tenants are attracted to the subject site.
Hill PDA’s analysis has shown a significant market gap will exist for LFR/bulky
goods floorspace in the trade area by 2016 and that this gap will grow
significantly in the future. Hill PDA note that the south-west region will be
27,000 sq.m under-supplied by 2016, and around 75,000 sq.m under-supplied
by 2026, even assuming the Turner Road precinct is fully developed.
Bringelly Road Business Hub
29
Net Community Benefit & Sequential TestSection 4: Review of Hill PDA Economic Impact Assessment
We consider that Hill PDA may slightly underestimate the overall demand for
bulky goods/LFR floorspace across the south-west region, as we consider the
target turnover level that has been applied in Table 4 (pg. 26) to be
unnecessarily high, at $3,600 per sq.m. We consider a level of around
$3,000 sq.m might be more appropriate and would represent a profitable
trading level, on average, for a broad range of bulky goods/LFR operators. That
said, we agree that there is currently considerable bulky goods/LFR demand
generated by the population in the south-west region and we note that future
demand is expected to grow from about 240,000 sq.m in 2014 to
417,000 sq.m by 2026, an increase of about 177,000 sq.m in 12 years or
about 14,750 sq.m per year.
In this context the proposed development concept at the subject site will only
absorb about 3 – 3.5 years’ worth of future demand generated by the
surrounding population, and this does not include potential demand from
beyond the south-west region attributable to the excellent road accessibly and
regionally oriented tenant mix.
The proposed LFR component of the development is expected to be staged,
with an initial stage of 30,000 sq.m planned to open in 2016/17 and a second
stage of about 20,000 sq.m is expected to be developed by 2018/2019.
We broadly agree with the analysis of trading impacts in the Hill PDA report, in
that impacts are likely to be distributed widely, across a range of
centres/precincts in the region. The Hill PDA analysis of economic impacts on
the surrounding centres network demonstrates that the proposed staging of
the project will serve to reduce any potential adverse trading impacts on
surrounding centres across the region. Furthermore, because there is such
significant market growth expected in the region, all centres/precincts stand to
benefit from this growth, and even with the proposed Bringelly Road
development, trading levels across most identified centres will be more than
20% above current trading levels (in constant dollar terms) by 2020.
We agree that the potential impacts that will be experienced by traditional
retail facilities and proposed traditional business centres such as the
Leppington Major Centre and Edmondson Park Town Centre will be negligible.
Bringelly Road Business Hub
30
Net Community Benefit & Sequential TestSection 4: Review of Hill PDA Economic Impact Assessment
We agree that the B5 zoned land in the Leppington North precinct suffers from
constraints in the way of land fragmentation and a lack of congruity limiting
the size of the largest potential precinct to about 15 ha. Furthermore, the land
is less well located from a regional accessibly perspective, with the Bringelly
Road Business Hub offering a considerably better location for regionally
oriented LFR facilities. We see both precincts operating complementary to each
other, serving different roles, with the Leppington B5 land providing smaller
scale tenancies or indeed a broad range of other possible uses.
The Hill PDA report identified a number of economic benefits associated with
the proposed development concept at the Bringelly Road subject site. We agree
with the key benefits identified, noting in particular that the project will provide
supportable jobs on-site, as well as create jobs across the broader economy
and during the construction phase of the project.
We note that Hill PDA has only considered the employment impacts associated
with the proposed LFR component of the development. Additional employment
will be supported as part of the supporting ancillary and light industrial uses,
both on site and during the construction phase of the project.
4.2 Other comments
We also make the following comments in relation to the Leppington Major Centre
and the retail sector, more generally.
Leppington Major Centre
The Sequential Test Analysis has shown that the proposed development could not
reasonably be accommodated within surrounding B5 zones and that the planned
B5 precinct within the Leppington North precinct faces a number of constraints
that would make development of the scale at the Bringelly Road subject site
impractical.
Bringelly Road Business Hub
31
Net Community Benefit & Sequential TestSection 4: Review of Hill PDA Economic Impact Assessment
In our view, the Leppington Major Centre will evolve to become a traditional retail
centre with a range of supermarkets, discount department stores (dds), specialty
retail and potentially department stores. We expect this development will be
staged, and is likely to only evolve well beyond 2020, when there is sufficient
critical mass in the immediate locality to support initial convenience facilities.
The surrounding B5 zoned land is most likely to play a support role for the Major
Centre, and is expected to include smaller scale localised bulky goods type
development, or enclosed bulky goods homemaker centre type floorspace, that
would be complementary to the LFR floorspace being considered at the Bringelly
Road subject site.
Notwithstanding that we expect the bulky goods development near the major
centre to be smaller scale (in terms of individual tenants), the B5 zone permits a
range of uses (that generally have large floorplates) that are intended to support
the role of centres. Such uses include light industrial uses, office uses,
hotel/accommodation uses, vehicle sales premises, recreation facilities and
community facilities to name but a few. In this context, the provision of a handful
of LFR tenants at the Bringelly Road subject site would not preclude bulky
goods/LFR, or indeed a broad range of other uses, from locating the B5 zoned
precinct adjacent to the Leppington Major Centre.
Future of retail sector
The retail sector is dynamic and evolves very rapidly. Therefore, future planning
for retail should contemplate and respond to new retail tenants and new retail
formats that might appear. Sites that offer flexible floorplates, excellent
accessibility and indeed a point of difference from a traditional centre, should be
encouraged and supported.
Only 11 years ago, in 2003, Aldi opened its first store in Australia. Now Aldi has
almost 400 stores and is rapidly expanding each year. Costco, a membership
based LFR bulk grocery operator has entered the Australian market within the last
5 years, with the first Costco store in Australia opening at Docklands in Melbourne
in 2009. By September 2013, Costco recorded in excess of $600 million in annual
sales/memberships.
Bringelly Road Business Hub
32
Net Community Benefit & Sequential TestSection 4: Review of Hill PDA Economic Impact Assessment
Only recently have major international mini-major fashion retailers such as Zara,
Top Shop, H&M, Uniqlo and Forever 21 entered the Australian marketplace, with
many more impeding arrivals and many unknown tenants likely to enter the
market in the next 5 – 10 years. Most of the early movers in this space have been
European or Japanese retailers, however, there are hundreds of other Asian,
American and European retailers who might consider the Australian market for
much the same reasons as the other major players. Australia is an affluent, fast
growing market and with large metropolitan cities and presents an opportunity for
at least several stores for any potential international retailer.
We do not suggest these types of fashion retailers be provided at the subject site,
merely we have discussed these retailers to show the trend of international
retailers hitting the Australian marketplace.
The future may bring new LFR/bulky goods type retailers that have a small
presence or are not yet present in the Australian market. IKEA has limited
presence in most capital cities (2 – 3 stores at most), but is considering rolling
out many more stores across the major metropolitan capital cities in the near
future. The subject site will provide large lot parcels under single ownership, at a
highly prominent location, which is regionally accessible to a large existing
population and significant future population.
We envisage a similar precinct to that which has emerged at Marsden Park
Industrial Precinct in the North West Growth Centre (NWGC), which will include
the likes of Bunnings, Masters, Costco, IKEA, amongst other potential tenancies.
While we do not suggest that all of these tenants will necessarily open at the
subject site, nor is the subject site dependent on these tenants for commercial
success, the above examples demonstrate that the proposed development would
be most appropriately located at a major road intersection, with regional
accessibility close to a major growth area – providing household type goods that
align with new dwelling growth in this area and is slightly different from existing
and proposed traditional retail facilities.
Bringelly Road Business Hub
33
Net Community Benefit & Sequential TestThis page has been intentionally left blank.
Section 5: Net community benefit test
This section of the report examines the net community benefits associated with
the proposed development were it allowed to be provided at the subject site. This
assessment examines the proposal against a base case, addressing the evaluation
criteria of the Draft Centres Policy net community benefit test.
A preliminary environmental assessment report, prepared in December 2013 by
JBA Planning, identifies a number of studies that will examine the various physical
impacts associated with a State Significant Development Application [SSD 6324]
for Bringelly Road Business Hub at Leppington.
Further, a retail demand and economic assessment has also been prepared by Hill
PDA in response to Director General’s Requirements (DGR’s) issued on 17 January
2014. In response to a minor boundary amendment and inclusion of proposed
light industrial land use, modified DGR’s for SSD 6324 were issued in April 2014.
It is understood that during the consultation and engagement process for SSD
6324, DPE requested a net community benefit assessment and sequential test be
undertaken.
This chapter considers technical consultant draft reports in relation to traffic,
environmental risk and infrastructure etc. being prepared as part of an
Environmental Impact Statement.
It combines the various assessments that have been undertaken thus far and
assembles these in a manner that attributes a net community cost or benefit to
the approval of SSD 6324 against a base case – i.e. were the Bringelly Road
Business Hub not to be developed.
Our assessment has been adapted from the evaluation criteria nominated in the
Draft Centres Policy.
Bringelly Road Business Hub
35
Net Community Benefit & Sequential TestSection 5: Net community benefit test
We have summarised the results of some of the quantitative criteria in the
following table.
Table 5.1
Bringelly Road Business Hub - Net Community Benefit Assessment
Status Quo - No Business Hub Proposed Business Hub Developed
Factor Costs Benefits Costs Benefits
Vehicle Km's Shoppers in trade area Reduction in vehicle kilometres
travelling further to access travelled due to provision of large
large format retail and format retail in trade area.
ancillary uses.
Choice / No additional choice or Additional large format operator in
competition competition would result. the trade area. This results in
improved choice and prices for
customers.
Environmental Uses are partly permissible Such uses are permissible Mitigation measures for removal
Impacts already and supportable already or otherwise may be of poor quality, low ecological
under S89E(3) of The EP&A supported under the SSD value woodland.
Act 1979. process.
Employment Could support some More employment as a result of
employment, but likely to larger format retail and service
be lower if only part of the centre.
site is developed
Housing No additional dwellings. No loss of residential land. No additional dwellings. No loss of residential land.
Retail Hierarchy No impact on centres No impact on centres Would not impact centres
Impacts hierarchy. hierarchy. hierarchy, and indeed, will
enhance the hierarchy by adding
a new node of LFR retail.
Infrastructure Would utilise existing and Would utilise existing and Will support improved access to
impacts planned road networks and planned road networks and future realigned Bringelly Road,
public transport routes. public transport routes. Site is via signalised intersection.
Upgrade to services may be serviced by water, sewage and
required. electrics.
Source: MacroPlan Dimasi
Bringelly Road Business Hub
36
Net Community Benefit & Sequential TestSection 5: Net community benefit test
Assessment against NCB evaluation criteria
Will the project be compatible with agreed State and regional strategic
direction for development in the area (e.g. land release, strategic
corridors, development within 800 metres of a transit node)?
The Bringelly Road Business Hub is situated adjacent to the South West Growth
Centre (SWGC) and is proximate to the urban development zoned suburbs of
Edmondson Park, East Leppington, Leppington, Leppington North and Austral. The
following key points are made in relation to the SWGC:
The South West Growth Centre is approximately 17,000 hectares in size and
includes parts of the Liverpool, Camden and Campbelltown LGAs.
It is divided into 18 Precincts that are being progressively released for planning
and rezoned for sustainable urban development.
The South West Growth Centre will be supported by a Major Centre at
Leppington and be serviced by the new South West Rail Link.
It will contain about 110,000 new dwellings for some 300,000 residents -
almost the same population as Canberra.
The subject site at Bringelly Road is located at the intersection of Cowpasture
Road and Camden Valley Way and is highly accessible to residents of the SWGC.
The subject site is proximate to the M5 an M7 Motorways, affording excellent
access to suppliers, employees and visitors.
The Bringelly Road Business Hub is an identified Business Hub in the WSPT Plan of
Management – Supplement (2012), which is the overarching strategic document
for the WSP. The identified business hubs in the WSP are intended to
accommodate commercially oriented uses that can generate financial returns for
the WSPT, that are in turn used to fund the upkeep, maintenance and
improvements to the parklands.
Bringelly Road Business Hub
37
Net Community Benefit & Sequential TestSection 5: Net community benefit test
The Hill PDA EIA report examined the potential economic impacts of the proposed
development on the surrounding network of centres in the region. That
assessment indicated that the proposed development will not affect the future
viability of any centres, including future proposed centres and B5 precincts.
Indeed, the proposed development will therefore not alter or impact the existing
strategic centres hierarchy, in particular those planned within the SWGC.
In this context, the proposed development at the subject site is consistent with
the strategic direction in the region.
Is the project located in a global/regional city, strategic centre or
corridor nominated within the Metropolitan Strategy or other
regional/subregional strategy?
The subject site is located within an identified Business Hub as identified within
the WSP Plan of Management (PoM) 2020. Further details of permissible land uses
and locations of business hubs are detailed in the approved Supplement to the
PoM.
The subject site is located at the intersection of Camden Valley Way, a key
economic development and transport corridor in the region.
Is the project likely to create a precedent or create or change the
expectations of the landowner or other landholders?
Liverpool Council has recently considered a variety of new zoning provisions in
response to growing demand to accommodate additional retail outlets across the
city. The proposal for this site is consistent with Council’s approach to allow for
retail competition in a manner that does not impact detrimentally on established
or planned centres.
The approach taken by Council facilitates a broader consideration of site worth in
the context of market need. The process of a focused assessment of site potential
State Significant Development application is consistent with planning law and
Bringelly Road Business Hub
38
Net Community Benefit & Sequential TestSection 5: Net community benefit test
practice. The proposed uses being considered at the subject site are permissible
(with consent) pursuant to the SEPP .
There is no substantive ground therefore to view the proposed development as
setting a precedent and the amount of supporting analysis/technical
documentation is consistent with the requirements of the SEPP, the issued
Secretary's Requirements and other requests including those of Liverpool Council.
Have the cumulative effects of other such projects in the locality been
considered? What was the outcome of these considerations?
Yes; the economic modelling that has been conducted by Hill PDA has had regard
for the cumulative effects of all approved and proposed developments across the
competitive network of relevance to the site. The Hill PDA EIA includes an analysis
of the potential impacts of the proposed development at Bringelly Road on the
surrounding network of centres/precincts of relevance.
The Hill PDA EIA showed that even with significant LFR/bulky goods development
expected at the Turner Road precinct in the future, there will be a significant
market gap for some 80,000 sq.m of LFR/bulky goods floorspace in the south-
west region by 2026. This gap will increase significantly in the future without
further provision of bulky goods/LFR floorspace.
The impact analysis showed that all surrounding centres in the region are
expected to be trading at levels considerably greater than current trading levels
(20% in constant dollars) in 2021, even with the proposed development at
Bringelly Road. This is because impacts will be broadly distributed across the
surrounding precincts and because there will be significant future growth in the
south-west region.
Will the project facilitate a permanent employment generating activity or
result in any impact on employment lands?
The proposed development is located within the WSP. A key objective of WSPT is
to generate employment. Residential accommodation is not permissible. The
Bringelly Road Business Hub
39
Net Community Benefit & Sequential TestYou can also read
