HUME CITY COUNCIL SUBMISSION - Delivering Melbourne's Newest Sustainable Communities - Parliament of Victoria
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HUME CITY COUNCIL SUBMISSION
Delivering Melbourne’s Newest
Sustainable Communities
HUME CITY COUNCIL SUBMISSION
Prepared by
Strategic Planning Team
Hume City Council
July 2009
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES
Contents
1.0 Introducon 5
2.0 Council Response to Melbourne@5Million 6
3.0 Delivering Melbourne’s Newest Sustainable Communies (DMNSC) 8
3.1 Consultaon Process 8
3.2 Precinct Structure Planning Process and Guidelines 9
3.3 Assessment of Invesgaon Areas 11
3.3.1 Employment: Discussion Paper 12
3.3.2 Transport Background Technical Report 14
3.3.3 Biodiversity Assessment: Melbourne North IA, Background Technical
Report 15
3.3.4 Infrastructure Background Technical Reports (Drainage/Trunk
Services) 16
4.0 Hume Growth Corridor 17
4.1 Urban Growth Boundary Alignment 19
4.1.1 R2 Supplementary Land (Area 3b & 3d – Mickleham Road East and
Inter-urban break) 20
4.1.2 Mickleham West (Land West of Mickleham Road) 22
4.1.3 Awood Employment Land 23
4.1.4 Merrifield West/North
(North/South Donnybrook Road along Mickleham Road) 24
5.0 Sunbury 25
5.1 Urban Growth Boundary Alignment 26
5.1.1 Transport 27
5.12 Sunbury West 28
5.1.3 Sunbury South 28
5.1.4 Sunbury Sanctuary 29
6.0 Implementaon 31
6.1 Issues with defining Developable Land and Non-Developable Land 32
6.2 Staging of Framework Plans and PSP’s 32
6.3 GAIC Funding for Precinct Structure Planning 33
6.4 Impacts on Municipal Administraon 33
HUME CITY COUNCIL SUBMISSION
7.0 Strategic Impact Assessment for the EPBC Act 35
7.1 Inconsistent methodology 36
7.2 Precinct Structure Planning 37
7.3 Conservaon of biological diversity and ecological integrity 38
8.0 Outer Metro Ringroad (OMR) & /E6 39
8.1 Key Idenfied Issues 39
8.1.1 Lack of benefit/ cost analysis (BCA) 39
8.1.2 Lack of traffic impact assessment 40
8.1.3 The Bulla Bypass and Melbourne Airport connecon 42
8.1.4 Connecon to Aitken Boulevard 43
8.2 Impact upon future public transport planning 44
8.2.1 Bus Review and bus planning 44
8.2.2 Addional public transport 46
8.2.3 Extension of northern rail electrificaon 46
8.2.4 Capital Works Programs – Arterial Road 46
9.0 Summary & Recommendaons 47
9.1 Alignment of Urban Growth Boundary 48
9.2 Strategic Impact Assessment for EPBC Act 49
9.3 Outer Metropolitan Ring Road (OMR) 50
Figures
Figure 1: Hume City Council, Urban Growth Boundary Alignment -
Submission to Melbourne@5Million 7
Figure 2: Hume Growth Corridor 18
Figure 3: R2 Supplementary Land to be considered for inclusion in UGB 20
Figure 4: Mickleham West Land to be considered for inclusion in UGB 22
Figure 5: Awood Employment Land to be considered for inclusion in UGB,
with Aitken Boulevard and Airport Connecon 23
Figure 6: Merrifield West North Land to be considered for inclusion in UGB 24
Figure 7: Sunbury Growth Area 26
Figure 8: Sunbury West Land for inclusion into UGB 28
Figure 9: Sunbury South Land for inclusion into UGB 28
Figure 10: OMR North Western secon 41
Figure 11: Aitken Boulevard - Future Transport Corridor 41
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES
Introduction
Delivering Melbourne’s Newest Sustainable Communies
(DMNSC), released 17 June 2009, included the release of four
iniaves. Of these four iniaves Council considers that the
following are specifically relevant to Hume City and will be
discussed throughout this Submission:
• The alignment of the Urban Growth Boundary surrounding
Sunbury and the Hume Growth Corridor and idenficaon of
developable and non developable land.
• The alignment of the Outer Metropolitan Ring Transit Corridor
(OMR)
• The Strategic Impact Assessment Report (SIA for EPBC Act)
This submission provides separate commentary relang to the
alignment of the proposed Urban Growth Boundary surrounding
both Sunbury and the Hume Growth Corridor. The submission
makes specific comment on the background technical reports
where relevant.
In addion the submission includes specific comment relang
to the SIA for EPBC Act as well as the proposed alignment of the
OMR. It is also important to note that this submission builds on
Council’s previous submission to Melbourne@5Million and the
direcons and principles applied within it.
HUME CITY COUNCIL SUBMISSION
Council Response to
Melbourne @ 5 MIllion
In February 2009, Hume City Council made a submission to the Based on these principles,
State Government following the release of the State Government’s Council’s submission to
Melbourne 2030: A Planning Update – Melbourne@5Million, Melbourne@5Million concluded
where Invesgaon Areas (IAs) were idenfied as part of the that the alignment of the
review of the Urban Growth Boundary (UGB). In the Submission Urban Growth Boundary within
to Melbourne@5Million, Hume City Council supported the State Hume City should be aligned
Government’s decision to review the current locaon of the UGB and as detailed in Figure 1 for the
the premise that new growth opportunies should largely be located two Invesgaon Areas located
within the north and west of Melbourne. in Hume City; Sunbury and the
Hume Growth Corridor.
Hume City Council’s Melbourne@5Million submission was prepared
with a view that the introducon of new areas within the UGB should It would appear that the
be underpinned by the principles listed below. planning principles that
informed the dra alignment
It was considered that these supported the vision and direcons set of the UGB are consistent with
out in Melbourne 2030: Planning for Sustainable Growth, October those that Council have
2002: adopted. Despite this, the
dra UGB alignment has failed
Urban Growth Boundary aligned with natural and physical boundaries to reflect these principles and
should be amended to include
Integrated new communies with populaon centres that efficiently areas as discussed in this
support community services and infrastructure submission.
Residenal areas located within close proximity to local employment This will provide an UGB
opportunies alignment that ensures that new
growth areas are sustainable
Development aligned with the delivery of supporng infrastructure into the future in line with the
including transport provision (arterial roads, electrificaon of rail, desired outcomes the State
freeways, Principle Public Transport Network - PPTN). Government is trying to achieve.
New growth areas should maximise use of exisng services and
facilies
Maintain adequate supply of land for residenal and commercial/
employment development
Land supply should allow for comprehensive and detailed planning of
areas including all uses not only housing supply
Where appropriate planning should be coordinated beyond municipal
boundaries (ie. creaon of communies or employment areas that
extend beyond municipal boundaries; Acvity Centre planning within
growth area context).
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES
Council Response to
Melbourne @ 5 MIllion
Councils proposed UGB alignment
supports sustainable growth areas
Figure 1: Hume City Council, Urban Growth Boundary Alignment - Submission
Melbourne@5Million
HUME CITY COUNCIL SUBMISSION
Delivering Melbourne’s Newest
Sustainable Communities (DMNSC)
Delivering Melbourne’s Newest 3.1 Consultaon In addion to the inadequate
Sustainable Communies meframes for Council to
includes three iniaves Process undertake a comprehensive
relevant to Hume City Council. review and assessment of the
This report details Council’s Delivering Melbourne’s Newest informaon it should be noted
response to the: Sustainable Communies, that the lack of me to prepare
which encompasses the four submissions is exacerbated
• Proposed UGB Alignment iniaves, is underpinned by a for affected and interested
for both the Hume Growth number of background technical landowners.
Corridor and Sunbury reports and specialist studies.
• Background technical The release of DMNSC has Four weeks is insufficient for
reports which support the provided a four week period for landowners to seek expert
UGB alignment both consultaon with affected advice on complex planning
• The SIA for EPBC Act stakeholders, as well the issues, to understand the direct
• OMR Alignment preparaon of submissions. implicaons of the many layers
associated with DMNSC as well
Whilst these are three separate Given the significance of all as preparing a submission.
iniaves, Council considers four iniaves, the complexity
that there are significant of informaon and the need It should be noted that the
relaonships that can be drawn to complete a review of all Department has asked Hume
between them. This includes material which has informed City Council to provide specific
the relaonship between decision making, Council feedback on the future of the
the UGB, future growth and considers the meframes municipality for the next 20
the alignment of the OMR. as inadequate and enrely years within a four week period.
Addionally there is a need for a unrealisc. It is submied that this is not
consistent applicaon of the SIA strategic planning, nor is it
for EPBC Act to areas which will Given the short meframes, allowing for a full consideraon
be included within the UGB and Council has not had of the factors that influence
their related biodiversity values sufficient me to complete a populaon growth, housing
to ensure a regional approach to comprehensive assessment of all diversity and employment
biodiversity protecon for new informaon which accompanies creaon, let alone transport and
growth areas is undertaken for DMNSC. The short meframes environmental issues.
all new areas of growth not only to make a submission have
the western areas. curtailed Councils opportunity
to consult with and seek
Four weeks is insufficient me
community input into the
development of this Submission.
to comment on a proposal
that will affect and inform
development and growth for
the next 20 years.
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES
Delivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.2 Precinct Structure in the growth areas. They
include the Government’s
Planning Process and objecves for growth area
Guidelines planning and describe a process
to achieve an integrated precinct
Direcon No. 12, issued by the structure plan.
Victorian Minister for Planning
on 10 June 2008, requires The new Delivering Melbourne’s
that in preparing a Precinct Newest Sustainable
Structure Plan for incorporaon Communies – Technical
into a planning scheme, the Reports rely heavily on the
relevant planning authority Precinct Structure Planning
must demonstrate that the process to collect further
Precinct Structure Plan, or any informaon to determine the
changes to it, are in line with development potenal of land.
any applicable Precinct Structure
Plan Guidelines approved by the Council is concerned with the
Minister. In October 2008, the reliance on the PSP Guidelines
Minister for Planning released as they yet to be finalised or
dra Precinct Structure Plan released by the Minister and
Guidelines (PSP Guidelines). nor have they been thoroughly
Since this me submissions tested through Planning
have been sought on the PSP Panels. Accordingly significant
Guidelines however they have reliance is being placed on a
connued to remain as a dra, largely untested process and
have not been approved by the development assumpons.
Minister and accordingly have Council believes that further
no formal status. invesgaon is required at a
higher strategic level prior to the
The PSP Guidelines are intended finalisaon and raficaon of
to set out what should be the proposed UGB.
addressed in preparing or
assessing a precinct structure
plan. They apply to new Too much reliance is being
residenal communies and placed on the yet to be
new major employment areas finalised PSP Guidelines and
untested PSP process.
HUME CITY COUNCIL SUBMISSION
Delivering Melbourne’s Newest
Sustainable Communities (DMNSC)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3 Assessment of These inconsistencies will be
outlined and discussed through
Invesgaon Areas out the remainder of this
submission in parcular with
Council supports the State reference to the alignment of
Government’s use of planning the UGB at Secon 4.1 and 5.1
principles to guide the UGB of this submission.
Review. In Council’s view the
Planning Principles adopted In addion it is understood that
by the State Government to the review of the Invesgaon
inform the new alignment of the Areas has been informed by the
UGB are generally consistent consideraon of key issues in
with those principles Council order to provide an economic,
adopted in its Submission social and environmental
to Melbourne@5Million raonale for the locaon of the
in February 2009. Council new UGB. This has included
considers these are integral to consideraon of Employment,
growth area planning and the Transport, Biodiversity and
consideraon of revised Urban Infrastructure.
Growth Boundary alignment.
Council provides the following
However it is disappoinng comments which are parcularly
that the State Government relevant to growth area planning
has not applied these Planning consideraons in response to
Principles consistently when the findings of the technical
proposing a dra UGB. reports and discussion paper.
HUME CITY COUNCIL SUBMISSIONDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3.1 Employment: Airport is expected to support
Discussion Paper over 55,000 jobs and the
Mickleham North Employment
One of the key objecves as Node is ancipated to support
part of DMNSC is to improve over 30,000 jobs. In addion
the distribuon of jobs so that the Broadmeadows Central
people can work closer to where Acvies District has been
they live. DMNSC recognises designated as an area of
that the benefits of this will significant employment growth
be reducing congeson on in the future.
roads and trains, the provision
of more equitable access to It is expected that Hume will
employment, and reduced connue to play a key role in
impacts on the environment. contribung to the naonal
economy and Australia’s global
Council supports this key posion, with an expectaon
objecve in the consideraon that employment will grow
of new growth areas and the between 90,000 - 95,000 jobs.
alignment of an UGB. Within
Hume City there are significant In 2003, following the release
areas idenfied for major of Melbourne 2030 Planning
employment opportunies, for Sustainable Growth and the
including Melbourne Airport introducon of the UGB, a Hume
and surrounds; Mickleham Commiee for Smart Growth
North Employment Node and (Commiee) was established
exisng industrial and business which examined growth and
park areas from Campbellfield development issues. As part of
extending along the Hume the Commiee’s deliberaons,
Freeway. it invesgated populaon, land
supply, economic acvity, social
These areas combined have the issues, environment values,
potenal to support a significant transport systems and other
number of jobs; Melbourne infrastructure within Hume City.
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3.1 Employment: Council has invested in making
Discussion Paper (cont...) land available for employment
purposes.
As a result of the
Commiee’s final report and Furthermore, it is Council’s
recommendaons to the cricism that the Employment
Minister for Planning, A Plan Discussion Paper has not been
for Melbourne’s Growth Areas specific regarding idenficaon
was released by the State of corridors within the
Government in November 2005. Invesgaon areas that are
appropriate for these significant
A Plan for Melbourne’s Growth areas.
Areas informed the amendment
of the UGB in the Hume The idenficaon of
Growth Corridor to provide employment areas should
730ha of addional land for have substanal impact on
residenal development and the allocaon and locaon of
1,175ha for employment residenal development and
purposes. Subsequently, the any associated infrastructure
State Government rezoned required for its integraon.
land inside the Urban Growth
Boundary from the Farming Whilst there is a set of
Zone to the Urban Growth Zone objecves, and spaal principles
and introduced a requirement relang to the funconality
to prepare Precinct Structure of employment precincts,
Plans. Council does not consider
these adequate to inform the
In 2008, land that forms part alignment of the UGB. Council
of the Mickleham North would like to see this finalised
Employment Node was rezoned prior to the compleon of the
in order to facilitate an increase UGB raficaon to ensure there
in the availability of land for is enough land conguously
employment purposes to located to ensure the success of
support new communies. This Employment areas.
addressed exisng inadequacies
in the supply of employment Hume City Council further
land, in parcular, supply supports the need put forward
to support large footprint by the Interface group of
employment uses. Councils that an employment
and investment strategy
The posion of this submission be delivered to guide the
is that the Employment installaon of infrastructure to
Technical Report prepared to support sustainable job creaon
inform the DMNSC did not within the growth areas.
adequately acknowledge the
HUME CITY COUNCIL SUBMISSIONDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3.2 Transport: This clearly highlights the This is an inadequate response
Background Technical gaps between infrastructure to an issue as crucial as the
provision, funding and future integraon of transport and land
Report
needs to service the growth use planning and is unlikely to
areas to ensure real integraon result in the State Government
Council supports the planning
of land use and transport. achieving the desired
principles that new growth areas
integraon.
and paerns of development
Moreover, the most northern
should allow for efficient public
areas of the Hume-Whilesea- This appears to be inconsistent
transport networks at a sub-
Mitchell IA surrounding with current State Government
regional level. In parcular the
Beverage require significant planning and objecves which
sub-regional public transport
investment in public transport aims to have every household
network should include
in order to effecvely and within a walkable 400m
connecons between residenal
sustainably service new growth. catchment of a bus route.
areas and key regional
employment areas.
The strategic transport response The distance of 3kms, equates
map (Background Technical to approximately a 30 minute
In order to truly deliver
Report: Transport) idenfies walk, which for many users will
“Melbourne’s Newest
that there are opportunies for be unacceptable in terms of
Sustainable Communies”
rail extensions into the north both personal mobility and me,
funding for transport
from the Craigieburn line and an and will therefore connue to
infrastructure needs to be
extension of the Epping line. exacerbate car dependence in
planned, funded and delivered
new growth areas.
in line with land release to
Both of these rail extensions
ensure effecve integraon of
are beyond the current scope
land use and transport.
and funding of the Victorian
Transport Plan, therefore
The majority of the new
require addional Government
infrastructure appears to be
commitment to fund.
beyond the current funding of
the Victorian Transport Plan.
It is also understood that
The Transport Background
an underlying principle for
Technical Report (p.15) notes
the development of new
that :“addional infrastructure
communies is for them to
that goes above and beyond
be planned within 3kms of a
the VTP horizon to deliver
mass transit route, yet many of
connecvity and capacity
these new mass transit routes
improvements specific to
are no more than idenfied
the requirements of the
opportunies in both terms of
Invesgaon Areas”.
planning and funding.
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3.3 Biodiversity This inconsistent approach, Council is concerned that
Assessment: Melbourne where informaon has been no further invesgaon has
based primarily upon modelling, been undertaken at this me
North IA, Background
and lile applicaon of – nor is any proposed prior
Technical Report ground-truthing, is parcularly to the finalisaon of the UGB
concerning with regards to the alignment.
Council understands that idenficaon of areas excluded
purpose of the Biodiversity from inclusion inside the UGB. Council acknowledges that there
Assessment: Melbourne North may indeed be some areas
IA Background Technical Report Also of concern is the limited where the Golden Sun Moth and
(Biodiversity Technical Report) invesgaon that has been associated vegetaon occurs.
was to locate areas of nave undertaken at this point for However, it is logical that these
vegetaon, or likely nave idenficaon of grassland areas are included within the
vegetaon that should be reserves to ensure that UGB unl the finalisaon of
retained in the event of changes migaon or offsets. ground-truthing and other
to the UGB. invesgaons have taken place
It should be noted that the to confirm these findings.
Council would like to highlight Biodiversity Melbourne North IA Council maintains that these
its disappointment with risk Technical Report acknowledges areas should not be excluded
based approach applied to that the Threatened Species from within the UGB.
the assessment of biodiversity Likelihood of Occurrence would
values in parcular nave typically rely upon detailed site Rather than excluding areas due
vegetaon and the presence of visits to verify the available to a lack of evidence or data
the Golden Sun Moth. habitat present on any given relang to crically endangered
site. flora or fauna, areas should
Furthermore, it would appear be included within the UGB
that there are significant Given the limited field to allow further invesgaon
inconsistencies between assessment that occurred on their true significance and
the assessment undertaken within the Melbourne North if any management outcome
within the Melbourne North IA, the list of species that are requirements.
Invesgaon Area and the considered likely to occur within
proposed alignment of the UGB. an invesgaon area should only To rule out specific areas at
This is parcularly concerning be used as a guide and not as this me and for the next 20
given the fact that it is the a definive list or species and years, based on insufficient
data collected through the their actual presence within the data collecon which is the
Biodiversity Technical Report invesgaon area. responsibility of a State
further informs the subsequent Government Department is not
SIA for EPBC Act. sasfactory.
Council has significant concerns with the inconsistent approach and assessment completed
for the idenficaon of biodiversity values.
A risk based approach to biodiversity values in the Melbourne North IAs will not lead to
improved outcomes or a holisc approach to biodiversity protecon.
Land should not be excluded from the UGB based on modelled biodiversity values.
HUME CITY COUNCIL SUBMISSIONDelivering Melbourne’s Newest
Sustainable Communities (DMNSC)
3.3.4 Infrastructure within Hume City as well as • trunk services within
Background Technical the need to plan to natural the invesgaon area
or physical boundaries as the appropriately, based on
Reports (Drainage / Trunk
extent of growth. This should earlier planning work
Services) avoid the alignment of the already undertaken.
UGB to arbitrary lines following • The mapping in the
Whilst the locaon of a new property boundaries and Appendix of the report
UGB should be considered in the situaons where pressures arise supports this view, with
context of the known constraints for further revisions of the UGB. most other Invesgaon
and land requirements and areas having exisng and
projected populaon growth, Within the Melbourne North IA, proposed infrastructure
it is also crical that new there are significant omissions clearly shown. In contrast,
growth areas and populaons regarding the appropriate the Melbourne North
can support the necessary mapping of locaons of IA is incorrectly labelled
infrastructure required. To available services, including, Donnybrook and includes
this end, it is crical that sewerage, electricity, gas and substanally less informaon
new growth areas are able to water reculaon which should than other maps. Compare
support the efficient provision have informed the alignment of Page 57 with Pages 55, 56
of infrastructure within a the UGB and 58, substanally less
catchment. informaon is shown on
There is generally a low level of the Page 57 map than these
An alignment of the UGB thoroughness and accuracy in other maps, without any
should be avoided where it will the reporng on trunk services explanaon as to why this is
create fragmented and isolated (Background Technical Report the case.
communies that cannot be 5: Trunk Services) parcularly
supported by infrastructure and as they relate to the Melbourne
service provision. North IA.
Small populaon centres which Evidence of this includes:
can not efficiently support
infrastructure result in increased • The Melbourne North IA
requirements and distances does not have its own
to travel for basic services and heading in the contents page
this has a significant impact on and is numbered under the
housing affordability. Emphasis Sunbury Invesgaon Area.
should be given to providing • Within the body of the
affordable living rather than report the Melbourne
focusing on the supply and cost North IA does not have its
of houses. own secon but connues
on from the Sunbury
The above menoned, in Invesgaon Area
considering the development • As noted earlier the extent
of new communies, should of invesgaon does
be one of the key factors that not appear to have even
informs the revision of the UGB idenfied the exisng
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESHume Growth Corridor
The Hume Growth Corridor has enjoyed consistent growth over
the past fieen years specifically in the areas of Roxburgh Park and
Craigieburn. Residenal growth within the Hume Growth Corridor
has also been supported by the development of employment areas.
Council considers that there are significant opportunies to build on
exisng growth areas and those currently being planned, specifically
in a westerly direcon towards Mickleham Road and beyond. This
will provide for the sustainable growth of the corridor in accordance
with the planning principles previously menoned; current precinct
planning and the recommendaons contained within the Commiee
for Smart Growth Report where future areas for growth were
idenfied.
Council considers that the following issues are integral to the
successful and long term sustainable development of the Hume
Growth Corridor:
Consistent applicaon of planning principles adopted to inform
the alignment of the UGB including the creaon of sustainable
community catchments
Use of exisng and planned infrastructure to promote efficiencies
Growth consistently contained within natural and physical
boundaries rather than arbitrary lines to allow proper orderly
planning for enre catchments
Ability to support residenal growth in close proximity to large
employment areas including, Mickleham North Employment
Precinct, Melbourne Airport and surrounds and Broadmeadows
Central Acvies District
Provision of efficient public transport networks at a sub-regional
level; including Orbital Bus Route along Mickleham Road, Bus Rapid
Transit along Aitken Boulevard (E14) and extensions to the exisng
Craigieburn train line
East West road links offer opportunies for SmartBus type orbital
services to link acvity centres, residents and employment nodes
and there would need to be planning and funding for these services
into the future
HUME CITY COUNCIL SUBMISSIONFigure 2: Hume Growth Corridor RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIES (Map Source: Hume City Council Submission to Melbourne@5Million)
Hume Growth Corridor
4.1 Urban Growth This is parcularly apparent
where land has not been
Boundary Alignment included within the UGB
along Mickleham Road.
Council supports the State The
This demonstrates limited
proposed alignment of the
understanding of the long term
UGB within the Hume Growth
planning objecves of the Hume
Corridor has excluded land along
Growth Corridor.
Mickleham Road.
It is vitally important that
The exclusion of land either
the revised UGB provide a
side of Mickleham Road to the
sensible and hard edge to
OMR is considered enrely
urban development if it is to
inconsistent with the planning
successfully place parameters
principles adopted to inform the
around the future growth of
alignment of the UGB.
Melbourne.
Most significantly, current
The dra UGB proposed for
precinct structure planning
the Hume Growth Corridor
for residenal areas has
connues the limitaons of the
included consideraon of
previous approach to releasing
future development towards
inconsequenal areas based on
Mickleham Road in an effort to
limited (and somemes flawed)
strategically plan a community
informaon with lile regard to
catchment, rather than small
the exisng subdivision paerns
inefficient areas which do not
and sustainable catchments.
support the necessary provision
of community infrastructure and
A more holisc approach to
other services.
defining the edges of the Hume
Corridor is vital to enable the
Unfortunately successive
UGB to efficiently limit growth
changes to the UGB in this
and land speculaon.
area have created small
isolated areas of development
Council considers that the UGB
that thwart any aempts to
alignment should be extended
strategically plan areas as
to the alignment of the OMR
sustainable communies with
as was previously submied
sufficient catchment.
in Council’s submission to
Melbourne@5Million as shown
Council is disappointed and
in Figure 1. The specific areas
frustrated that the dra
are discussed in further detail in
UGB appears to connue to
the following pages.
exacerbate disjointed and
insufficient catchments.
HUME CITY COUNCIL SUBMISSIONHume Growth Corridor
4.1.1 R2 Supplementary Land (Area 3b & 3d – Mickleham
Road East and Inter-urban break)
It is understood this land
has been excluded based on
biodiversity values.
Excluding this land primarily as
a result of biodiversity values is
inconsistent with the approach
applied for the alignment of the
UGB in other areas.
A clear example of the
inconsistency in seng the
UGB alignment can be seen in
comparing Figures 40 and 43 of
the Background Technical Report
2b, Biodiversity Assessment:
Melbourne North IA that Land for
idenfy Strategic Habitat Links. Inclusion
Figure 40, Invesgaon Area 3A:
Analysis of Biological Constraints
idenfies a significant area
between Merri Creek and the
Sydney Melbourne Railway Line
(Donnybrook staon) area as
a strategic habitat link, with
significant amounts of biological
constraint and yet this area
is idenfied as being ‘Land
Suitable for Development’ by
the Melbourne’s North Land Use
and Transport Iniaves Map. In
comparison, it is extraordinary
that all of the R2 Supplementary
Land is excluded from the UGB
even though the extent of the
strategic habitat links, Figure 43,
suggests this is not warranted.
Figure 3: R2 Supplementary Land to be considered for inclusion in UGB
(Map Source: DMNSC - Report for Consultaon)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESHume Growth Corridor
4.1.1 R2 Supplementary Land (Area 3b & 3d – Mickleham
Road East and Inter-urban break) cont ...
The R2 Supplementary land should be included within the UGB
and it is considered that the inclusion of this land within the UGB is
consistent with the planning principles.
The inclusion of the R2 Supplementary Land, west and north of the
Craigieburn R2 Precinct Structure Plan (PSP) will deliver specific
benefits including:
• Ulisaon of exisng reculated trunk infrastructure
• Ulisaon of exisng and planned social infrastructure within the
catchment
• Provides addional catchment to enhance the viability of
the Craigieburn Major Acvity Centre where major social
infrastructure is planned
• Integraon with land north of Donnybrook Road currently
proposed for inclusion inside the UGB for residenal purposes.
The proposed UGB alignment results in an isolated community
north of Donnybrook Road with limited connecons to southern
parts of growth corridor and insufficient catchments
• Ability to properly plan major road networks and connecons to
OMR
• Opportunies for a coordinated biodiversity protecon response
building on land already inside the UGB (Mt Ridley Grasslands and
Folkestone Employment Precinct Woodlands);
• Opportunity for this area to add value to the adjoining urban area
through provision of alternave land uses (school site or other
social infrastructure)
In addion it should also be noted that the Biodiversity Technical
Report (Figure 27) idenfies more than 50% of land within the R2
Supplementary Land, Invesgaon Area 3D, as having No Nave
Vegetaon. This indicates that these areas have potenal for urban
development, parcularly in the context of the urban development
currently being planned directly to the east (Craigieburn R2 PSP).
This land must be included within the UGB as provides for the
development of a sustainable catchment east of Mickleham Road,
building on already planned and developed communies, as well as
allowing the exisng and planned infrastructure to be ulized to its
full capacity.
HUME CITY COUNCIL SUBMISSIONHume Growth Corridor
4.1.2 Mickleham West The inclusion of the remainder
(Land West of Mickleham of land between Mickleham
Road and the OMR increases
Road)
the catchment, populaon size
and promotes an efficient use of
In Council’s previous Submission
services and community facility
to Melbourne@5Million it was
provision west of Mickleham
submied that land west of
Road.
Mickleham Road to the Outer
Metropolitan Ring Road should
In addion, the OMR offers
be included within the UGB.
the opportunity to provide for
This land is not included within
a major physical barrier to the
the proposed UGB.
extent of westerly growth within
the Hume Growth Corridor. In
Current precinct structure
other circumstances, parcularly
planning for a small area inside
within the Melbourne West
the UGB west of Mickleham
IAs and more northern areas
Road (R3 Greenvale West) has
of Melbourne North IA, this
demonstrated its isolaon,
principle of using defined
challenges associated with
physical and natural edges to
servicing and community
development has been adopted.
infrastructure provision, as well
It is not clear why this principle
as poor connecons to land east
can not be applied in this area.
of Mickleham Road.
Land for
Inclusion
Figure 4: Mickleham West Land to be considered for inclusion in UGB
(Map Source: Hume City Council Submission to Melbourne@5Million)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESHume Growth Corridor
4.1.3 Awood The possible development of
Employment Land this land for the purposes of
a High Tech Business Park is
For some me now Council enrely consistent with the
has considered the Awood protecon of the long term
Employment land as an area operaon of Melbourne Airport
that should support the and its status as a 24hour curfew
development of a High Tech airport.
Business Park.
The connued exclusion of
Since the introducon of the the Awood Employment
UGB Council has connually land inside the UGB is enrely
advocated for the inclusion at odds with the planning
of this land inside the UGB, principles adopted that have
yet the Awood Employment informed the UGB alignment.
Land has sll not been included
within the UGB. To date the This land is strategically located
State Government has failed to and has the potenal to create a
provide Council with adequate high quality employment area in
advice on why this land is proximity to exisng residenal
connually excluded from areas and new areas.
development.
The Awood Employment land
also provides a key link from
Hume Corridor to Melbourne
Airport and would facilitate the
extension of Aitken Boulevard
(E14) creang much needed
links with the potenal to
provide Bus Rapid Transit to
Land for linking employment areas within
Inclusion Hume City to both exisng and
residenal areas. This land must
be included within the UGB.
Figure 5: Awood Employment Land to be considered for inclusion in UGB,
with Aitken Boulevard and Airport Connecon
(Map Source: Hume City Council Submission to Melbourne@5Million)
HUME CITY COUNCIL SUBMISSIONHume Growth Corridor
4.1.4 Merrifield West/ A preliminary analysis also
North (North/South suggests that the proposed
UGB alignment does not allow
Donnybrook Road along
the development of sufficient
Mickleham Road) catchments to provide the range
of services required to support
The proposed UGB currently a stand along community that
aligns with the OMR in this area, would be created.
Council considers that a more
appropriate alignment is the Movement of the UGB to the
natural boundary west of the natural boundary along old
OMR where a ridge line occurs Sydney Road would improve
along Old Sydney Road. This opportunies to create a
provides a more disnct edge to more sustainable catchment
growth within this area. and ensure consideraon of
appropriate connecons to the
This would allow proper OMR can be realised.
planning of the interface with
the OMR and connecons to
Aitken Boulevard (E14) and
potenal urban areas to the
north. The current alignment
of the UGB will make Merrifield
West/North essenally land
locked and enrely reliant on
Land for
connecons to Donnybrook
Inclusion
Road.
This would also allow any shi in
the OMR to be accommodated.
Figure 6: Merrifield West North Land to be considered for inclusion in UGB
(Map Source: DMNSC - Report for Consultaon)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESSunbury
Hume City Council welcomes the consideraon of Sunbury as a
growth area and supports the extension of its UGB. Council has ad-
vocated since 2002 for a revision of the UGB around Sunbury in order
to facilitate growth opportunies that contribute to the creaon of
crical mass sufficient to enhance service provision. The dra align-
ment of the UGB is generally consistent with Council’s planning for
the future growth of Sunbury.
Whilst the changes to the UGB around Sunbury are generally sup-
ported Council would like to highlight the following idenfied issues
and important consideraons:
The pressing need to deliver capacity enhancements to the nearing
capacity Sunbury-Bulla Road however, it is unclear how this issue
will be dealt with in the short to medium term prior to the OMR.
Imperave that the principle of infrastructure lead development
growth is applied to new areas in Sunbury parcularly in regards to
the provision of public transport. It appears that a major commit-
ment beyond the Victorian Transport Plan is required to deliver new
communies within Sunbury.
Provision of employment areas within Sunbury and the relaonship
with other employment areas within Hume City.
Growth consistently contained within natural and physical boundar-
ies rather than arbitrary lines or tle boundaries to provide a defi-
nite boundary to growth and to allow populaon catchments that
can efficiently support the provision of services and infrastructure;
Sequencing of development to support upgrading of trunk infra-
structure and drainage requirements;
The need to ensure the integrity of significant landscape elements
and values is maintained.
HUME CITY COUNCIL SUBMISSIONSunbury
5.1 Urban Growth Council’s previous submission
Boundary Alignment to Melbourne@5Million
advocated that the UGB should
be aligned with natural features
The proposed alignment
and physical boundaries rather
of the UGB has included a
than an arbitrary line or tle
significant area of land and
boundary. The use of Jacksons
has generally included all land
Creek and Emu Creek creates a
which was included within
definite boundary and supports
the Melbourne@5Million
this principle, however areas
Invesgaon Areas. This
to the west and south have
is consistent with Council’s
not always been aligned with a
posion that Sunbury should be
physical boundary when there is
recognised as a growth area.
opportunity to do so.
Council is disappointed however,
that addional areas idenfied
in Council’s Submission to
Melbourne@5Million have not
been included within the UGB.
Council considers that the
UGB alignment should be
extended to include land to
the west and south of Sunbury
as was previously submied
in Council’s submission to
Melbourne@5Million and
shown in Figure 1.
Figure 7: Sunbury Growth Area
(Map Source: Hume City Council Submission to Melbourne@5Million)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESSunbury
5.1.1 Transport
The proposed alignment of the UGB within Sunbury and the future development of land
will require a major commitment to provide the necessary infrastructure, specifically
transport related infrastructure to support growth.
Council would like to see an integrated approach to transport infrastructure planning that
considers the following:
Within the Sunbury Township, the two proposed staons to the North, and South of the
exisng staon are supported by Council, however there needs to be a commitment
from Government in terms of delivery of these staons in order to effecvely plan
and service the precinct, along with improvements to the range and frequency of bus
services.
With the proposed electrificaon to Sunbury due to be finished in 2012, links into the
city centre, and desnaons along the rail line (Sydenham, Footscray CAD) will become
more aracve opons for residents, however the response to Sunbury’s transport
needs sll remains largely radial, when in fact the journey requirements of residents are
largely either internal (within the Sunbury catchment) or orbital (easterly to the airport
and Hume corridor) in nature. Sunbury is a key desnaon in itself for local residents,
2006 JTW data indicates that the majority of Sunbury workers work within the Sunbury
SLA, followed then by those heading east to access employment opportunies in the
Hume Corridor (Broadmeadows and Craigieburn SLAs). The third most important JTW
desnaon is Melbourne.
Melbourne Airport remains a key desnaon for Sunbury residents. It is likely that the
importance of Broadmeadows CAD as a key desnaon will be strengthened into the
future, and also the Craigieburn Town Centre to the North of the Hume Corridor will
emerge as a key acvity centre. Access to these three acvity centre desnaons is
accessed via, and constrained by, Sunbury Road. Sunbury Road is for the most part
a single lane rural grade road that has a very steep and sharply curved route through
Bulla where it negoates a gorge. This reduces the capacity of the route and limits the
opportunies for deliverable capacity enhancements.
Currently there is only one (hourly) bus service that negoates this route, the 500
which travels via the airport and on to Broadmeadows. Under the proposed opons
put forward under the current Victorian Bus Review it has been recommended that
this route be split, requiring a change at Melbourne airport to connue on the access
the range of services available in the CAD. Council strongly opposes this: What is
required instead is not the obliteraon of the current route, but rather the investment
into strengthening the route, increasing service levels and frequency, thus making it a
viable alternave to the car when accessing the range of services available in the Hume
Corridor. Without the requisite investment into service infrastructure along this route,
car dependency will connue to rise, pung increased pressure on an already congested
road.
HUME CITY COUNCIL SUBMISSIONSunbury
5.1.2 Sunbury West 5.1.3 Sunbury South In addion, the land is ideally
(land between Gap Road (Land east of the railway located to support local
and Reservoir Road to the line and Calder Freeway employment based uses as a
result of its proximity to the
Calder Freeway) and bounded by Jacksons
potenal alignment of the
Creek and the potenal OMR and connecons to Calder
A small area of land has been alignment of the OMR) Freeway.
omied from the inclusion of
the proposed UGB between An area of land east of Vineyard The provision of employment
Gap and Reservoir Roads and Road has been included within land supports the need to
the Calder Freeway. This land the proposed UGB. However, provide jobs in close proximity
should be included within the a large area outside this should to residenal areas.
UGB as it will extend the exisng also be included.
residenal areas to a clear
physical boundary being the This would allow the extension
Calder Freeway. of residenal development
to provide a larger catchment
This area is flat with no known which could beer support
constraints, can be easily a train staon and transit
serviced from the exisng orientated development. The
development and provides OMR also provides a physical
crical mass in the west creang boundary to the extent of
opportunity to develop a new growth as does Jacksons Creek.
neighbourhood acvity centre
to service the western areas of
Sunbury.
Land for
Inclusion
Potential
Figure 8: Sunbury West Land for inclusion Train
Station
into UGB
(Map Source: Hume City Council Submission Land for
to Melbourne@5Million) Inclusion
Figure 9: Sunbury South Land for inclusion into UGB
(Map Source: Hume City Council Submission to Melbourne@5Million)
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESSunbury
5.1.4 Sunbury Sanctuary Schedule to the Green Wedge
(Land to the north of A Zone to allow an increase in
Sunbury and west of density over about one third of
the land with the trade off being
Enterprise Drive)
to rezone the remaining two
thirds from Green Wedge A Zone
Although not included in the IA’s
to Rural Conservaon Zone.
there should be consideraon
for the role the land known as
The amendment represents
The Sanctuary could play in the
an appropriate response to
protecon of biodiversity and
the significant environmental
offsets for Sunbury. Council
constraints on the land by
would like to ensure the
prevenng inappropriate
facilitaon of a good outcome
subdivision and ensuring areas
for this land as it contains
containing significant nave
significant remnant vegetaon
vegetaon are protected and
but is poorly managed and
rehabilitated.
suffers from severe erosion and
degradaon. In actual fact the
Council believe the amendment
land is degrading and eroding
will provide a net community
into Jackson’s Creek causing
benefit and is significant in
further problems. A soluon
terms of the proposed future
needs to be found that restores
growth of Sunbury and the
the land and minimises further
need to balance biodiversity
degradaon.
conservaon. Accordingly, this
land should be considered as
Council has resolved to request
part of the broader planning and
authorisaon from the Minister
biodiversity conservaon for the
for Planning on an amendment
Sunbury Township.
that seeks to amend the
HUME CITY COUNCIL SUBMISSIONSunbury
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESImplementation
Council’s previous submission to Melbourne@5Million idenfied
the need for an appropriate implementaon strategy to support a
revised UGB. Council considers an implementaon strategy crical
to delivering DMNSC. Hume City Council supports the proposed
approach to develop Growth Area Framework Plans which consider
sequencing prior to the development of Precinct Structure Plans.
The Growth Area Framework Plans need to provide:
Refinement of the boundaries between developable and non
developable areas,
High level land use guidance prior to future planning processes
(i.e. Precinct Structure Planning). An advantage of providing this
guidance is that it will ensure that land best suited for employment
purposes is designated for this purpose,
City wide framework on acvity centre locaons,
City wide framework on road and other transport infrastructure
parcularly the Principal Public Transport Network,
Sequencing of PSP’s and consideraon of the need to balance
delivery of residenal areas and employment areas to promote job
opportunies are available in close proximity to residenal areas
In addion Council is also concerned on the reliance of Growth Area
Framework Plans to provide more informaon on constraints which
should inform the UGB alignment. Moreover significant reliance is
being placed on a process to which there is lile detail on how it will
occur, what the process will involve as well as the meframes for
delivery.
HUME CITY COUNCIL SUBMISSIONImplementation
6.1 Issues with The most significant of these 6.2 Staging of
defining Developable Land concerns is the rigour with Framework Plans and
and Non-Developable Land which land will be defined PSP’s
as developable or non-
developable. The inclusion of addional
It is understood that a process of
defining Developable and Non- land within the Urban
Unless considerable rigour is Growth Boundary provides an
Developable land will follow
applied to defining developable opportunity to appropriately
the seng of a new UGB and
and undevelopable land it is stage the implementaon
be part of the development of
highly likely that upon more of Framework Plans and
Growth Area Framework Plans.
detailed analysis, land that was Precinct Structure Plans to
It is understood that the Growth
first thought to be developable ensure that effecve planning
Area Framework Plans will
will be found to have significant is undertaken for the areas
also include the designaon of
constraints. This is parcularly included for development.
future residenal, employment
relevant for biodiversity values
and other land uses within
as has been previously discussed Failure to stage the
those areas idenfied for
where there is more detailed implementaon of Framework
development.
analysis required. Plans and Precinct Structure
Council supports the Plans is likely to result in poor
The ramificaons of this for planning outcomes due to the
preparaon of Growth Area
applying the GAIC could be limited planning resources
Framework Plans for these
significant. Therefore the available to plan significant
purposes however there are
Growth Area Framework Plans areas effecvely.
concerns with how such work
will have to be prepared using
will be implemented parcularly
sufficient levels of invesgaon To ensure that adequate
in relaon to the proposed
and delivering sufficient levels of resources are deployed
Growth Area Infrastructure
certainty to avoid this problem. to deliver robust planning
Charge (GAIC). For this process
to work effecvely the Growth outcomes it should be clear
Area Framework Plans should to all stakeholders what
provide the basis for the staging arrangements will be
applicaon of the UGB. in place for the preparaon of
Framework Plans and Precinct
The applicaon of the UGB Structure Plans.
without any framework has the
potenal to make subsequent
preparaon of Growth Area
Framework Plans, Precinct
Structure Planning and
implementaon of the GAIC
unworkable.
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESImplementation
6.3 GAIC Funding for Precinct Structure Planning
There is a significant amount of uncertainty surrounding the Growth
Area Infrastructure Charge (GAIC). Council supports the principle
of some of the increased value arising from the planning decision
to release land for urban development to contribute towards the
infrastructure required to service these areas.
It is important however that the landowner or organisaon that will
benefit from the release of the land for urban development and
the increase value or profits associated make the contribuons.
Accordingly Council submits that it is imperave that the GAIC
is equitable and does not unfairly burden landowners. To this
end Council considers that the implementaon of the GAIC and
applicaon of when it applies requires parcular aenon.
This should include consideraon of:
• Land within the inter-urban break that may transfer ownership
but does not realise a development opportunity
• Small land parcels
• Area of non developable land, which in some circumstances may
not be idenfied unl the Precinct Structure Planning stage
The GAIC will be available for Precinct Structure Planning and
the Development of Growth Area Framework Plans. It would be
beneficial for coordinated planning outcomes if a proporon of the
GAIC was set aside for such purposes.
6.4 Impacts on Municipal Administraon
As discussed in Hume City Council’s submission to Melbourne@
5Million, Council considers that the alignment of a new UGB will
impact significantly on Municipal administraon and long term service
planning.
Accordingly, there is a requirement to understand the impacts and
resourcing requirements within growth area municipalies to deliver
development which is in addion to areas already being planned for
within the UGB.
HUME CITY COUNCIL SUBMISSIONSunbury
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESStrategic Impact Assessment
for the EPBC Act
Council acknowledges that the Strategic Impact Assessment (SIA)
Report includes the Invesgaon Areas which have been idenfied
in Melbourne@5Million. These Invesgaon Areas and the corridors
for the related transport project proposals (the OMR/E6 Transport
Corridor and Regional Rail Link) lie in the broader regional context
of metropolitan Melbourne and surrounding region (Victoria in the
Future 2008).
Within the SIA it is stated that the report is based on an integrated
planning approach to provide for long-term reconciliaon of a range
of economic, environmental, social and equitable consideraons.
Council believes that this is not the case and challenges the
assumpon that DMNSC has reconciled economic, environmental and
social consideraons, parcularly in relaon to the omission of the
area east of Mickleham Road into the UGB.
One parcular priority of the Delivering Melbourne’s Newest
Sustainable Communies is to opmise the use of exisng
infrastructure systems (transport, water, drainage, sewerage, power),
in terms of both economic efficiencies and environmental costs, and
to ensure that new urban areas are planned around high capacity
public transport facilies. Council believes it has idenfied instances
where this principle has been applied inconsistently, and where there
needs to be a review of the any analysis supporng the removal of
areas based upon inadequate modelling of vegetaon or habitat
values.
HUME CITY COUNCIL SUBMISSIONStrategic Impact Assessment
for the EPBC Act
7.1 Inconsistent Also of concern is the limited There are a number of
invesgaon that has been compeng issues within
Methodology undertaken at this point for this precinct that have been
idenficaon of grassland discussed in other areas of this
Council would firstly like to submission.
reserves to ensure that
acknowledge and commend the
migaon or offsets can be
strategic approach undertaken To propose that land with some
achieved at a regional level
within the Melbourne West potenal biodiversity value
within the Melbourne North IA.
Invesgaon Area, and also will be retained and protected
within surrounding areas. by excluding it form the UGB
Council does not believe that
Given the obvious importance shows a naive understanding of
the approach is consistent
of nave grassland within the the realies of land use in non
with the stated objecves of
Melbourne West Invesgaon urban areas adjacent to urban
the assessment. At the same
Area and areas further west development.
me the assessment has been
that have been idenfied
used to define future land use
as potenal new grassland Council also challenges the
outcomes based on limited
reserves, considerable effort has methodology used is the best
informaon.
ensured sound data collaon available informaon on maers
and modelling in these areas to of naonal environmental
Whilst at one level the
inform the proposed protecon significance within the area to
assessment is described as a
program. provide an overall assessment
high level invesgaon which
does not necessarily need to at a strategic level of likely
The considerable effort impacts on these maers, and
provide detail on specific sites it
undertaken during the survey what major migaon iniaves
is has also been used to define
work and ground-truthing has would be required to reduce
future land use outcomes
resulted in a robust framework or where possible reverse net
based on limited informaon.
for protecon of significant impacts.
Council considers that where
vegetaon types and will
locaons of strategic significance
result in a strategically situated There are a number of
are omied on the basis of
grassland plain into the future. inconsistencies between the
biodiversity values, that there
should be detailed analysis to known habitat locaons and
Council however is disappointed those mapped within the SIA
demonstrate why the area has
with the risk based approach for EPBC Act and Biodiversity
been omied from the UGB.
and the inconsistency that has Melbourne North IA Background
been undertaken within the Technical Report.
Melbourne North IA.
The approach applied where
informaon has been based
primarily upon modelling,
and lile applicaon of
ground-truthing is parcularly
concerning as it has been used
to idenfy areas to omit from
the new UGB.
RESPONSE TO DELIVERING MELBOURNE’S NEWEST SUSTAINABLE COMMUNITIESYou can also read
