DFC - Am GC28 Donnybrook & Woodstock PSP - …...Mahew Lee CV Urbis advice to Stockland 25 October 2011 Boral – Am GC28 Donnybrook & Woodstock PSP – Economic witness statement

Principal Ma�hew Lee ma�[email protected] (03) 8825 5895 Project Code DD1607 Date 9 May 2016

Disclaimer

This report has been prepared by Deep End Services Pty Ltd for the purpose of providing expert evidence to Planning Panels Victoria and for use by the party to whom it is addressed. Accordingly, any changes to this report will only be no�fied to those par�es. Deep End Services Pty Ltd, its employees and agents accept no responsibility or liability for any loss or damage which may arise from the use or reliance on this report or any informa�on contained therein by any other party. Deep End Services Pty Ltd gives no guarantees or warran�es as to the accuracy or completeness of the informa�on contained in this report when it has been provided by a third party.

Table of Contents

1. Introduc�on ....................................................................................................... 1

2. Amendment GC28 .............................................................................................. 5 3. Donnybrook / Woodstock PSP ............................................................................ 8

4. Review of Essen�al Economics ......................................................................... 12

5. Submission 13 .................................................................................................. 23 6. Assessment of Am GC28 ................................................................................... 25

7. Summary of opinion ......................................................................................... 40

A�achments:

Ma�hew Lee CV

Urbis advice to Stockland 25 October 2011

Boral – Am GC28 Donnybrook & Woodstock PSP – Economic witness statement – M Lee deep end services pty ltd 1

1. INTRODUCTION

1.1 Instruc�ons

1. I have been instructed in this ma�er by HWL Ebsworth, ac�ng on behalf of DFC (Woodstock) Pty Ltd (‘Client’).

2. The ma�er relates to Amendment GC98 to the Whi�lesea and Mitchell Planning Schemes (‘Am GC28’) which has been prepared by the Metropolitan Planning Authority (‘MPA’) to implement the Donnybrook / Woodstock Precinct Structure Plan (‘PSP’).

3. Am GC28 facilitates development and use of land within the PSP area by introducing the Urban Growth Zone (‘UGZ’) Schedule 6 to the Whi�lesea Planning Scheme and the UGZ Schedule 4 to the Mitchell Planning Scheme, as well as numerous other changes to zones, overlays and clauses to the respec�ve planning schemes as detailed in the Explanatory Report.

4. DFC has major interests in the PSP as the owner of land marked as Proper�es 30, 31, 32, 33 and 37 within the Woodstock part of the PSP area, and Property 16 within the Donnybrook part of the PSP area. The PSP iden�fies a Local Town Centre (‘LTC’) to be developed within the DFC landholding.

5. My instruc�ons in this ma�er were received from HWL Ebsworth by correspondence on 31 March 2016 as follows:

Our Client wishes to engage you to:

§ Prepare evidence rela�ng to economic issues rela�ng to our Client’s land as a result of Amendment GC28. This evidence is likely to focus on issues raised by Submission 13 rela�ng to Lockerbie Town Centre.

6. The tasks completed in the prepara�on of this statement have included:

§ Reading and considering the exhibited documenta�on and relevant background reports;

§ Reviewing relevant submissions; § Undertaking my own assessment of likely dwelling and popula�on yields across the

PSP area; § Undertaking an assessment of the planned ac�vity centres hierarchy as proposed

under Am GC28, including considera�on of resultant delivery of retailing services to local residents;

§ Examining issues related to Submission 13; § Preparing this economic statement suitable for provision to Planning Panels

Victoria.


7. I have also been instructed by Norton Rose Fulbright to provide evidence at Am GC28 on behalf of Boral Resources (SA) Limited, in rela�on to issues associated with Submission 27 and the proposed reloca�on of town centres in the Donnybrook part of the PSP.

8. Common aspects of my analysis on behalf of Boral have been included in this statement where relevant.


1.2 Expert witness details

Name and address of expert

Ma�hew Lee Principal Deep End Services Pty Ltd Suite 304 / 9-11 Claremont Street South Yarra VIC 3141

Expert’s qualifica�ons and experience • Bachelor Degree in Commerce from the University of Melbourne. • Principal of Deep End Services since April 2012. • Consultant with Essen�al Economics from 1997 to 2012. • Prac�sing urban economist since 1995.

A full CV is included as an a�achment.

Expert’s area of exper�se • Urban and regional economics including contribu�on to land use planning studies. • Market demand analysis for property development including retail, commercial, industrial

and residen�al. • Input to strategic planning studies including Urban Design Frameworks, Structure Plans

and Master Plans. • Ac�vity centre network planning.

Expert’s exper�se to make report • Experienced in urban and regional economic analysis including considera�on of impacts

arising from retail developments. • Experienced in prepara�on of market assessments for new retail and mixed use

developments. • Past involvement in strategic planning in rela�on to ac�vity centre development, including

as lead author of the Ac�vity Centre and Employment Planning report for the (former) Growth Areas Authority.

Instruc�ons that defined the scope of the report • My instruc�ons were received from HWL Ebsworth on 31 March 2016 as detailed in

Sec�on 1.1 of this statement.

Facts, ma�ers and assump�ons upon which the report proceeds

Stated in relevant sec�ons of this statement.

Documents, materials and literature used in preparing this report

Stated in relevant sec�ons of this statement.


Iden�ty of the person who carried out any tests or experiments relevant to this report

I was assisted in my analysis by Lara Series, Analyst at Deep End Services.

Summary of the opinions of the expert

A summary of my opinions is presented in Sec�on 6 of this statement.

Provisional opinions not fully researched

None.

Ques�ons outside the expert’s exper�se

None.

Report incompleteness or inaccuracies

None.


2. AMENDMENT GC28

9. Am GC28 has been prepared by the MPA to apply to approximately 1,785 hectares of land included within the Donnybrook/Woodstock PSP area, located approximately 35km north of Melbourne CBD as shown in Figure 1.

Figure 1: Donnybrook / Woodstock PSP loca�on

Source: Deep End Services


10. The PSP area is bounded by the alignment of the proposed Outer Metropolitan Ring (‘OMR’) to the north-east, Donnybrook Road to the south and the Melbourne-Sydney railway line to the west, as shown in Map 1 of the Am GC28 Explanatory Report which is reproduced as Figure 2 below.

Figure 2: Land affected by Am GC28

Source: Am GC28 Explanatory Report Map 1

11. Land to the north-east and east of the PSP area is beyond the Urban Growth Boundary (‘UGB’) and within the Green Wedge Zone (‘GWZ’).

12. Land to the south-east of the PSP is within the GWZ.

13. Land to the south of Donnybrook Road is partly within the planned Northern Quarries Inves�ga�on Area for which structure planning has yet to take place. An Addendum to the North Growth Corridor Plan envisages some residen�al development on that part of the inves�ga�on area (approximately 253 hectares) located immediately to the south of the


Donnybrook / Woodstock PSP. My calcula�on of the poten�al residen�al yield and popula�on capacity within this area, and the implica�ons for centre networks in Donnybrook/Woodstock, is provided later in my statement.

14. Land to the south-west of the PSP area, south of Donnybrook Road, is within the English Street PSP which was approved through Am C183 to the Whi�lesea Planning Scheme in February 2016.

15. Land to the west of the Melbourne-Sydney railway line is within the Lockerbie PSP area which was approved in June 2012.

16. Am GC28 proposes to make changes to the Whi�lesea and Mitchell planning schemes to facilitate development and use of land by:

§ Introducing UGZ Schedule 6 to the Whi�lesea Planning Scheme and applying it to the amendment area

§ Introducing UGZ Schedule 4 to the Mitchell Planning Scheme and applying it to the amendment area

§ Incorpora�ng the Donnybrook/Woodstock Precinct Structure Plan (November 2015) into the Whi�lesea and Mitchell planning schemes and lis�ng this document in the Schedule to Clause 81.01

§ Applying the Public Acquisi�on Overlay (PAO) to some parcels of land outside the PSP area

§ Making numerous changes to the planning scheme including rezonings and applica�ons of overlays as listed on pages 2 and 3 of the Explanatory Report.

17. The amendment provides for the development of approximately 16,600 new homes (Explanatory Report, p3), open space, community facili�es, schools, spor�ng reserves, bus capable roads and a network of ten Local Town Centres (‘LTCs’) and Local Convenience Centres (‘LCCs’).

18. Clause 2.2 and Table 1 of the proposed UGZ6 to the Whi�lesea Planning Scheme specifies that land iden�fied ‘Retail’ in the Future Urban Structure plan has the Commercial 1 Zone (‘C1Z’) provisions applied.

19. Clause 2.5 of UGZ6 makes specific provisions for the use of land, and in Table 2 specifies that a permit is required for shop use if the combined leasable floor area of all shops exceeds the following limits for each of the iden�fied LTCs and LCCs:

§ LTC1: 21,500sqm § LTC2: 10,000sqm § LTC3: 4,500sqm § LTC4: 2,000sqm

§ LCC1: 1,000sqm § LCC2: 2,500sqm § LCC3: 1,000sqm § LCC4: 500sqm § LCC5: 1,500sqm

DFC (Woodstock) – Am GC28 Donnybrook & Woodstock PSP – Economic witness statement – M Lee deep end services pty ltd 8

3. DONNYBROOK / WOODSTOCK PSP

20. The PSP is a long-term plan for urban development that aims to provide a diverse mix of residen�al neighbourhoods linked by a network of local town centres and supported by schools and other community facili�es.

21. Relevant Objec�ves for the PSP are:

§ Provide high amenity and vibrant town centres that cater for residents various shopping, service, employment, entertainment and accommoda�on needs

§ Create ‘main street’ focused town centres that encourage community interac�on and promote medium and higher density housing on land in and adjacent to town centres

§ Encourage development around the Donnybrook and Lockerbie Sta�ons that capitalise on opportuni�es to be proximate to the transport hubs

§ Promote local employment opportuni�es to meet the varied needs of exis�ng and future residen�al popula�ons and encourage counter-cyclical travel pa�erns to alleviate conges�on on Melbourne’s roads

§ Encourage the �mely provision of local community infrastructure and convenience retail to meet the daily needs of residents within the precinct.

22. The Vision an�cipates improvements in access to and within the precinct, including:

§ Upgrades to Donnybrook road to create a primary arterial road § An extension of Gunns Gully Road into the precinct to act as a primary arterial road,

providing a connec�on for PSP residents to the future Lockerbie Principal Town Centre to the west and a future connec�on with the OMR to the east, with a Public Acquisi�on Overlay (‘PAO’) providing for a full interchange at this intersec�on

§ Development of Cameron Street to support east-west movement, and Pa�erson Drive to support north-south movement

§ A second north-south arterial at Koukoura Drive from Donnybrook Road to Gunns Gully Road for residents within the Woodstock PSP

§ A fine grain street network to form a permeable grid pa�ern to promote walking and cycling in order to reduce car dependence for daily ac�vi�es.

23. Table 1 of the PSP (p13) provides a summary land use budget with calcula�ons of net developable area (‘NDA’). I note that the accompanying text (last line on p13) states that Table 1 provides es�mated dwelling yields, but these are not included in the table.


24. A number of Requirements and Guidelines listed in Sec�on 3.1 in rela�on to Housing are relevant in assessing the planned retail network:

§ R20 and R21 provide minimum average dwelling densi�es for various areas across the PSP. I understand that these requirements have been amended by the MPA as follows:

- R20 to apply only to land within 800m of the Donnybrook Train Sta�on, with a new R21 to apply to land within 800m of the planned Lockerbie Train Sta�on

- R20 and R21 (as amended) to require a minimum 25 dwellings per net developable hectare (‘NDH’) within 500m of each sta�on (as measured form the forecourts) and 18 dwellings/NDH from 500m to 800m of each sta�on

- R22 (new) to apply to land within 400m of each Local Town Centre requiring a minimum 18 dwellings/NDH.

§ G8 states that subdivision of land should create an overall average density greater than 15 dwellings/NDH

§ G9 is intended to encourage a diversity of lots including detached dwellings, dual occupancies, semi-detached dwellings, townhouses, terraces, row houses and walk-up flats and apartments.

25. Sec�on 3.2 provides guidance on Town Centres and Employment, and Table 3 (p19) sets out a summary of the an�cipated retail and commercial floorspace outcomes and the roles that each centre will play in the hierarchy. Addi�onal guidance on the preferred design of each centre is provided in Appendices 4.2 and 4.3 of the PSP.

26. I note that there is a discrepancy between the floorspace shown for Woodland LCC5 in the table (1,500sqm retail and 500sqm commercial) and the informa�on on the Woodland Urban Design Framework (‘UDF’) in Appendix 4.3 which shows 1,000sqm specialty retail and no commercial floorspace. I have adopted the informa�on from Table 3 as this is replicated in UGZ6.

27. Lockerbie is located in the adjoining PSP to the west but is included in Table 3 to show that it will play an important role as the regional focus for retail, community, business/employment and residen�al uses. Total retail floorspace of 80,000sqm reflects the as-of-right allowance for Shop use under UGZ5 to the Hume Planning Scheme.

28. LTC1: Koukoura Drive (21,500sqm retail and 6,200sqm commercial) is intended to play a sub-regional role with the inclusion of a discount department store (‘DDS’) and is to be co-located with a range of educa�on and community infrastructure including library. Higher density housing is envisaged as part of the centre concept.

29. LTC2: Pa�erson Drive (10,000sqm retail and 5,500sqm commercial) is a neighbourhood centre serving residents in the southern, central part of the PSP and is co-located with schools, community facili�es and spor�ng reserves.


30. LTC3: Lockerbie East (4,500sqm retail and 2,200sqm commercial) is a smaller neighbourhood centre serving the north-west part of the precinct adjacent to two primary schools.

31. LTC4: Darebin Creek is a small centre (2,000sqm retail and 500sqm commercial) posi�oned in the south-eastern part of the precinct to the east of Darebin Creek, adjacent to two primary schools.

32. Six LCCs are described in Table 4 on p13 of the PSP, ranging in size from LCC2 Donnybrook Sta�on (2,500sqm retail and 4,500sqm commercial) to LCC4 Hayes Hill (500sqm retail). These centres are distributed across the PSP to fills gaps in the spa�al distribu�on of centres.

33. The informa�on in Table 3 of the PSP and the further informa�on provided in the individual Urban Design Frameworks for each centre have been summarised in Table 1 below which shows the an�cipated retail (by type) and commercial floorspace at full development.

34. The retail floorspace distribu�on by type for Lockerbie has been broadly es�mated to conform to advice on centre development and staging within the Lockerbie PSP prepared by Urbis on behalf of Stockland Developments by le�er dated 25 October 2011 (included as A�achment 2).

Table 1: Summary of town centre floorspace by type

Source: Donnybrook / Woodstock PSP Note: floorspace alloca�ons for Lockerbie indica�ve, based on advice to Stockland from Urbis (October 2011)

35. Total development within the PSP is an�cipated to comprise 46,000sqm of retail floorspace and 20,900sqm of commercial floorspace at capacity.

Centre Dept store

Disc dept store

Super-market

Speciality retail

Total retail Commercial

ExternalLockerbie 15,500 19,000 10,000 20,500 65,000 40,000 - 50,000

Local town centreLTC1: Koukoura drive 0 7,000 5,500 9,000 21,500 6,200LTC2: Patterson drive 0 0 5,000 5,000 10,000 5,500LTC3: Lockerbie east 0 0 2,500 2,000 4,500 2,200LTC4: Darebin creek 0 0 1,500 500 2,000 500

Local convenience centreLCC1: Donnybrook farmhouse 0 0 0 1,000 1,000 0LCC2: Donnybrook station 0 0 1,500 1,000 2,500 4,500LCC3: Lockerbie station 0 0 0 1,000 1,000 1,000LCC4: Hayes hill 0 0 0 500 500 0LCC5: Woodlands 0 0 0 1,500 1,500 500LCC6: Merristock 0 0 1,000 500 1,500 500

Total within PSP area 0 7,000 17,000 22,000 46,000 20,900

Floorspace (sqm)


36. According to Sec�on 3.2 on Centres and Employment (refer Table 5, p20), the PSP will accommodate an an�cipated 3,316 jobs, including an es�mated 540 jobs (or 16%) associated with retail and commercial ac�vity within town centres.

37. This is a significant under-es�mate of the level of new employment likely to be generated by the proposed retail and commercial floorspace. For example, by applying broad rule-of-thumb floorspace-to-employment ra�os for each use type, I es�mate that total employment could be close to 2,000 jobs within the iden�fied town centres, as shown in Table 2 below.

Table 2: Es�mated town centre employment crea�on


38. The proposed size of each centre in terms of retail and commercial floorspace is supported by retail-economic analysis presented in the Essen�al Economics report of June 2014, with addi�onal advice provided to MPA by correspondence in June 2015.

Type Floorspace Sqm/job JobsDDS 7,000 60 115Supermarket 17,000 28 605Specialty retail 21,500 55 390Total retail 45,500 41 1,110Commercial 20,900 25 835Total 66,400 34 1,945


4. REVIEW OF ESSENTIAL ECONOMICS

39. Am GC28 is informed by the Regional Town Centre and Employment Land Assessment report prepared by Essen�al Economics (‘EE’) in June 2014 (‘2014 report’) which provided advice to the MPA regarding the poten�al size and role of nominated town centres in the Donnybrook/ Woodstock PSP.

40. EE provided further advice in a le�er headed Advice on the Future Urban Structure for Donnybrook and Woodstock PSPs dated 25 June 2015 (‘2015 advice’).

4.1 2014 report

41. The report was commissioned to provide an assessment of the town centre and employment land requirements for a Study Region consis�ng of:

§ Donnybrook/Woodstock PSP § English Street PSP (now completed) § Northern part of Northern Quarries Inves�ga�on Area (now iden�fied as poten�al

PSP 69.1 to include residen�al and employment ac�vi�es).

42. For the purposes of examining the 2014 Report and undertaking addi�onal inves�ga�ons, I have excluded the English Street PSP area where possible, as this area provides for its own local retail facili�es and also relies on the Lockerbie South LTC to its north. In my opinion centre development within Donnybrook/Woodstock PSP will be of li�le relevance to people living within the English Street PSP area.

43. The following paragraphs present a review of the approach, inputs and findings of the 2014 Report, along with my comments on aspects of this analysis where relevant.

Methodology

44. EE have adopted a methodology which has been used in a number of similar reports produced on behalf of the (former) Growth Areas Authority (‘GAA’) and the MPA. The broad structure of their approach is as follows:

§ Es�mate the total NDA of land within the Study Region by applying a development efficiency rate to the gross land area a�er excluding larger tracts of land encumbered by waterways or land which has biodiversity of environmental significance

§ Es�mate the future dwelling yield by applying an average dwelling density § Es�mate the likely future popula�on at full development by applying an average

household size to the dwelling yield § Forecast the spending capacity of PSP residents at full development (in 2040) based

on average spend per capita for different retail categories in 2013 and applying real growth over the intervening period


§ Es�mate the poten�al share of retail spending in each category that would be retained by centres within the PSP area/Study Region

§ Incorporate spending drawn from beyond the PSP to generate total retail sales at PSP centres in 2040, and convert to floorspace by applying average turnover performance levels for 2013 and incorpora�ng real growth over the 2013-2040 period.

45. In addi�on to the above analysis which provides an es�mate of total supportable retail floorspace within the PSP area, further capacity analysis has been undertaken to examine whether there is sufficient demand to support a DDS and to es�mate the amount of supermarket floorspace that could be supported at centres within the PSP.

46. I accept that the EE approach is consistent with retail-economic analysis that has been undertaken to support other PSPs in Victoria, and is an approach that has informed Panel on many occasions. However, my opinion is that this methodology is unnecessarily complex and requires a large number of assump�ons or es�mates including, in the case of the 2014 Report:

§ Development efficiency rate to convert gross land to NDA § Average dwelling density § Average household size § Average per capita spending base for 2013 § Real growth rates for each retail category to forecast average per capita spending to

2040 § Market shares for each retail category to iden�fy ‘retained’ spending within the PSP

area § Share of total turnover for PSP centres captured from beyond the PSP area, for each

retail category § Es�mated average trading levels in 2013 for each retail category § Real growth rate to forecast average trading levels in 2040 for each retail category.

47. Of par�cular concern are the assump�ons about spending levels and turnover performance which rely on es�ma�ng current averages and then applying a compounding real growth rate to generate a forecast level of average retail spending and average retail turnover performance over a period of 27 years from 2013 to 2040.

48. My calcula�ons of supportable retail floorspace presented in Sec�on 6 of this statement instead rely on an average provision rate approach, which can be applied directly to the capacity popula�on forecasts in order to calculate supportable retail floorspace. This is provided as an alterna�ve and simpler way in which the Panel can assess whether the PSP retail network responds appropriately to likely future retail demand.

49. The following sec�ons summarise and comment on par�cular aspects of the 2014 Report.


Total dwelling yields

50. The total NDA across the PSP is calculated by assuming an overall development efficiency rate of 70%, having excluded larger tracts of encumbered land. This is an appropriate approach in the absence of more detailed informa�on.

51. Three dwelling yield scenarios are based on densi�es of 15 dwellings/NDH, 16.5 dwellings/NDH and 18 dwellings/NDH. These are typical rates experienced in many other PSPs, but may understate the likely dwelling yields in this PSP where higher densi�es are mandated close to Donnybrook and Lockerbie (proposed) railway sta�ons.

52. The resultant dwelling yield for the Donnybrook/Woodstock PSP is es�mated at 13,300 to 15,960 dwellings within the PSP area, with another 2,030 to 2,440 dwellings in the future Northern Quarries residen�al area. My opinion is that these are under-es�mates of the likely eventual dwelling yield, as I demonstrate in Sec�on 6.

Total popula�on within the PSP

53. The 2014 Report calculates the popula�on outcome for each density scenario by applying an average household size of 2.8 persons per dwelling.

54. I note that in other similar reports by EE on behalf of the GAA or MPA, a range of average household sizes has been adopted, typically from 2.8 to 3.0 persons per dwelling. In the most recent example I can find, the adopted average household size was 3 persons per dwelling in the EE background report tendered to the Panel for the Wollert PSP (Whi�lesea Am C187).

55. In my opinion a figure of 2.8 persons per dwelling is likely to underes�mate the eventual popula�on outcomes in the PSP and wider Study Region, as I demonstrate in Sec�on 6.

56. The total popula�on within the PSP (ie excluding English Street PSP area) is es�mated at:

§ High dwelling density: 44,700 persons § Medium dwelling density: 40,960 persons § Low dwelling density: 37,240 persons.

57. The addi�onal popula�on forecast for the Northern Quarries PSP is:

§ High: 6,830 persons § Medium: 6,270 persons § Low: 5,680 persons.

58. Subsequent analysis proceeds by adop�ng the medium density scenario which would consist of 40,960 persons within the PSP and another 6,270 persons within the Northern Quarries PSP area. Given that the eventual development density is likely to be at the upper end (or exceed) the range projected by EE, the subsequent analysis using the Medium popula�on scenario is likely to under-es�mate long term retail needs.


Future retail expenditure

59. My preference is to avoid the use of average per capita retail spending es�mates and forecasts because of the lack of exis�ng demographic data to assign a base es�mate, and the difficulty in projec�ng these values forward over an extended 27-year period (to 2040).

60. The EE report adopts a ‘base’ spending profile which reflects the wider northern growth area, which I consider to be appropriate in the absence of alterna�ve data, but could be improved by modelling on other recently-developed growth areas.

61. From the 2014 Report I calculate that the real growth rates applied to each spending category range from 0.26% pa for Food, liquor and groceries (‘FLG’) to 2.0% pa for Retail services. By comparison, Deep End Services subscribes to detailed commodity-based spending forecasts prepared by Deloi�e Access Economics which extend out to 2027. This dataset includes forecasts of price and volume effects, with an implicit real growth rate for Food spending of approximately 0.5% per year.

62. This discrepancy highlights the difficulty in projec�ng retail spending by category over large periods.

63. Total retail spending by Study Region residents is forecast to be $869.7m in 2040 (expressed in 2013 dollars), no�ng that this has been calculated from the Medium popula�on scenario and includes spending by people living in the English Street PSP area. Excluding English Street, total retail spending capacity is forecast to be $815.2m.

Indica�ve market shares

64. Retail spending retained to support development at centres located within the Study Region has been forecast by es�ma�ng the share (‘market share’) of total retail spending that would be retained at centres within the Study Region.

65. Market shares have been es�mated under two centre network scenarios:

a. Scenario 1: A network that only consists of supermarket-based LTCs with one supermarket each

b. Scenario 2: A network that would allow for one centre to have a more significant sub-regional role with addi�onal non-food shopping, and with some centres to contain more than one supermarket.

66. Although some jus�fica�on is provided for the adopted market shares, this process is necessarily somewhat subjec�ve. Overall, the aggregate market shares range from 31% under Scenario 1 to 41% under Scenario 2.

67. A rule-of-thumb is that supermarket-based neighbourhood ac�vity centres typically account for approximately 25% to 35% of total retail floorspace in metropolitan regions. With supermarkets usually the highest average traders (ie in $ per sqm terms), this outcome is supported by the EE market shares adopted for Scenario 1.


68. Scenario 2 includes a more significant increase in market share for Non-food retailing (increasing from 10% to 25%), reflec�ng the influence of a DDS and other non-food majors, mini-majors and specialty shops. These values appear reasonable a�er considera�on of the further analysis provided subsequently in the DDS capacity assessment.

Total turnover

69. Total aggregate turnover achieved by centres within the Study Region is calculated by applying the market shares and then accoun�ng for in-coming spending by people living beyond the region.

70. The resul�ng forecasts are for total turnover of $297.6m under Scenario 1, or $401.7m under Scenario 2. Note that these figures incorporate sales at poten�al centres within the English Street PSP and Northern Quarries PSP areas.

Supportable retail floor space

71. A key step in the EE methodology is to convert the projected centre turnover into supportable floorspace. This involves es�ma�ng current retail performance in 2013 and projec�ng to 2040. Total sales divided by average sales per sqm of retail floorspace represents the amount of floorspace that can be supported locally.

72. As I have noted earlier, the adop�on of trading performance es�mates and applying compound growth rates over long �me periods is difficult and cau�on should be exercised in interpre�ng this analysis. EE properly notes that the results should be seen as broad indica�ve es�mates of future retail need, with more detailed analysis accompanying planning permit applica�ons.

73. The conclusions drawn by EE are that total supportable retail floorspace is approximately 33,000sqm under Scenario 1, and approximately 45,000sqm under Scenario 2.

74. Average retail provision rates would be 0.7sqm/capita under Scenario 1 and 0.9sqm/capita under Scenario 2. Compared against forecast total retail demand of 2.5sqm/capita, these represent 28% to 36%, respec�vely, of total retail demand generated by Study Region residents, which is acceptable given the neighbourhood-level facili�es provided under Scenario 1 and the inclusion of sub-regional shopping at one centre under Scenario 2.

DDS capacity analysis

75. Addi�onal useful analysis in the context of Scenario 2 is provided with the inclusion of the DDS capacity assessment presented in Table 4.7 of the 2014 Report, which examines whether the spending capacity within the Study Region is sufficient to support a DDS within one of the LTCs.

76. EE make the statement that “a general rule is that a core catchment of approximately 40,000 to 50,000 persons is required to support a DDS and the associated specialty retail that is accommodated in a sub-regional shopping centre” (p41). With a popula�on of


45,000 to 55,000 people within the Study Region, the conclusion is made that there is prima facie a sufficiently-large catchment to support sub-regional facili�es.

77. I have previously noted that residents within the English Street PSP are unlikely to direct their shopping to centres within the Donnybrook/Woodstock PSP. The resul�ng popula�on, at 42,920 to 51,530 persons, is within the range indicated by EE as suppor�ng a DDS.

78. As I demonstrate later in this statement, the typical catchment for a DDS in outer suburbs is in fact lower than 40,000 to 50,000, adding to the strength of support for a DDS within the PSP.

79. The capacity analysis in Table 4.7 proceeds by:

§ es�ma�ng the size of the market available to a DDS as a propor�on of total non-food spending

§ es�ma�ng the share of this market likely to be captured by a local store § including spending from beyond the Study Region § incorpora�ng sales of food-related merchandise § calcula�ng the resultant likely future turnover of a local DDS § conver�ng to floorspace by applying an average trading level of $4,000/sqm.

80. The analysis indicates that supportable DDS floorspace would range from 4,900sqm to 7,400sqm depending on achievable market shares. Further commentary is provided to recommend that one of the centres within the PSP should have the flexibility to accommodate a DDS should sufficient demand eventuate, and that this centre should be posi�oned approximately 4km distant from Lockerbie PTC to minimise compe��on effects.

Supermarket development poten�al

81. A similar capacity analysis is performed to examine how much supermarket floorspace could be supported within the Study Region under each centre development scenario.

82. The analysis incorporates es�mates of supermarket spending, the share of the spending market retained in local centres, addi�onal sales to people living beyond the Study Region and non-food sales to arrive at total es�mated turnover poten�al for all Study Region supermarkets. This is then converted to supportable supermarket floorspace by applying an average trading level of $10,500/sqm.

83. The conclusion is that 15,500sqm of supermarket floorspace would be supportable under Scenario 1, and 17,000sqm supportable under Scenario 2 (refer EE, Table 4.8).

84. When compared against the forecast popula�on at capacity (and excluding English Street PSP), I calculate that the average supermarket floorspace provision would be 0.30sqm/cap under Scenario 1 and 0.33sqm/cap under Scenario 2. These calcula�ons are made against the High popula�on scenario, reflec�ng my view that EE has under-es�mated the likely popula�on outcomes.


85. As I demonstrate in Sec�on 6, the resul�ng supermarket provision rates are lower than I would expect to be supportable given exis�ng average provision rates in Melbourne’s outer LGAs.

Implica�ons for Lockerbie PTC

86. Sec�on 4.7 of the 2014 Report considers the poten�al effect on the planned Lockerbie PTC as a result of the proposed quantum of floorspace to be developed within the adjacent Donnybrook/Woodstock PSP.

87. EE highlight the fact that centres within the PSP would capture a minority of the spending and retail development poten�al generated by local residents, with a large share of spending directed to higher-order centres outside the Study Region (this is termed ‘escape spending’).

88. By es�ma�ng the share of escape spending that may be directed to Lockerbie, EE conclude that this spending flow would assist in establishing Lockerbie as a significant regional shopping des�na�on as planned, par�cularly as Lockerbie will become a des�na�on for future residents within a much wider region extending across the northern growth corridor.

89. I agree with this conclusion.

Centre loca�ons and size

90. More detailed guidance on the spa�al distribu�on and proposed size of individual town centres is provided in sec�ons 4.9 and 4.10 of the 2014 Report. This analysis considers indica�ve core catchments served by a network of centres to determine the likely distribu�on of supermarkets as the anchor use within each centre, based on a one-supermarket-per-centre model. A summary is presented in Table 3.

Table 3: EE supermarket floorspace outcomes

Source: Essen�al Economics 2014 Report (Table 4.12)

91. The key finding is that a network of 5 supermarket-based centres would be supported, with the centres marked ‘C’ and ‘D’ in Figure 4.3 of the 2014 Report (reproduced in Figure 3) having poten�al to accommodate full-line supermarkets. However, EE note that the total supermarket floorspace provision under this network is lower than the es�mated 15,500sqm to 17,000sqm assessed as being supportable, and conclude that some centres could accommodate more than one supermarket.

Centre Supermarket floorspace (sqm)

Centre A 800Centre B 2,500Centre C 4,000Centre D 4,000Centre E 800Total within PSP 12,100


92. Subsequent analysis considers the effect on the network if mul�ple supermarkets are considered for some centres, with the results summarised in Table 4 and showing more significant supermarket floorspace for centres C and D.

Table 4: EE supermarket floorspace outcomes with mul�ple supermarkets

Source: Essen�al Economics 2014 Report (Table 4.14)

93. I generally support the EE conclusions with respect to the appropriate network of centres, although my analysis indicates there may also be poten�al for a smaller LTC to be accommodated in the Northern Quarries PSP area, to be examined when that PSP is prepared.

94. I also note that provision for a (possible) supermarket is now provided in the English Street PSP.

95. Sec�on 4.10 of the 2014 Report considers some par�cular issues, including which of the centres would be the most appropriate to accommodate a sub-regional role with the inclusion of a DDS. There is a discrepancy in this analysis, as the text on p57 of the 2014 Report states that ‘Centre D’ would be the preferred loca�on, but the subsequent analysis on pp58-59 specifies that ‘Centre C’ would accommodate addi�onal floorspace.

96. My conclusion from the reference on p57 to “maximum separa�on from Donnybrook PTC” is that ‘Centre C’ is the one iden�fied as accommoda�ng a sub-regional role. This is a reasonable conclusion that is supported by my own analysis.

97. EE also considers the effect on centre loca�ons arising from the high pressure gas mains dissec�ng the PSP, leading to an eastwards shi� in the loca�on of ‘Centre C’ and a westwards shi� in the loca�on of ‘Centre D’.

98. I note that Figure 4.5 of the 2014 Report also shi�s ‘Centre D’ southwards towards Donnybrook Road (refer Figure 4). I understand that for various reasons this loca�on is unsuitable and the loca�on has been moved northwards to its current posi�on.

Centre Supermarket floorspace (sqm)

Centre A 800Centre B 2,500Centre C 6,000Centre D 6,000Centre E 800Total within PSP 16,100


Figure 3: EE 2014 Report core catchments for preliminary centre loca�ons

Figure 4: EE 2014 Report implica�ons of the gas pipeline in the Study Region


4.2 2015 advice

99. The 2015 Advice was prepared to review the dra� Future Urban Structure (‘FUS’) plan for the PSP and provide updated recommenda�ons on the poten�al size and role of nominated town centres. I note that the dra� FUS is broadly similar to the exhibited version in terms of the loca�ons of each centre.

100. The main relevant conclusions are summarised below, referencing Figure 1 of the 2015 Advice which is reproduced as Figure 5.

101. Centre 1 is the largest centre, planned to accommodate a library and community services facility as well as nearby schools. While not centrally-posi�oned with respect to the PSP as a whole, the centre has fewer development constraints than Centre 2 and is considered appropriately located to have an elevated sub-regional role with the inclusion of a DDS.

102. Centre 3 would be a neighbourhood shopping centre of up to 6,000sqm according to the 2014 Report. EE observe that this centre is important to improve access to local services for the community living in the north-eastern part of the PSP, but would have a smaller core catchment. Higher densi�es around the centre would help to maximise the catchment popula�on to support the smaller LTC.

103. Centre 4 is iden�fied as a small LTC that will provide access to convenience shopping and other facili�es. EE acknowledge that this centre serves a smaller catchment and would sit within the shadow of the larger Centre 1.

104. The 2014 Report iden�fied an opportunity for a small LTC at Centre 5 close to Donnybrook Sta�on. According to the 2015 Advice, the dra� FUS iden�fies this as a LCC, with a small LTC located at Centre 6 north of the Donnybrook Farmhouse. EE advise that Centre 5 should be retained and expanded in size due to the increased residen�al densi�es close to the sta�on, with Centre 6 relegated to an LCC role with an alloca�on of 0.5ha.

105. I note that the exhibited PSP retains the LCC classifica�on for the town centre at Donnybrook Sta�on, even though this has a floorspace alloca�on of 2,500sqm retail and 4,500sqm commercial floorspace and is envisaged to include a small supermarket. I support the EE advice that this should be designated as an LTC.

106. In rela�on to Centre 7 at the proposed Lockerbie Sta�on, EE highlight the need for flexibility around future land development poten�al given the uncertainty surrounding the eventual land uses within Lockerbie PTC.

107. The loca�ons for other LCCs are supported, with a recommenda�on that 0.5ha be included within these centres to enable future development poten�al.


Figure 5: 2015 Advice – Figure 1 dra� Future Urban Structure and centre loca�ons

4.3 Conclusions

108. The EE methodology is somewhat complicated but the recommended retail network is appropriate in terms of the broad scale and components of each centre. In par�cular, my own analysis (refer Sec�on 6) supports the conclusion that a network of five centres each of which accommodate one or more supermarkets is appropriate, and that one of these centres could also accommodate a DDS.

109. I support the proposed spa�al arrangement of centres across the PSP area, no�ng the constraints associated with the gas pipeline, the railway line on the western boundary (with limited road crossings) and the posi�on of Lockerbie PTC further to the west.

110. I acknowledge and support the commentary provided with respect to Centre 5 in Figure 5 above which seeks to protect and promote this centre’s role as an LTC close to a railway sta�on.

111. I acknowledge and support the finding that Centre 3 serves a marginal catchment for a full-line supermarket but is important to ensure appropriate access to services, and that the role of Centre 4 is limited by the catchment size and the loca�on of Centre 1 nearby.


5. SUBMISSION 13

112. I have been instructed to examine issues raised in Submission 13 which has been made on behalf of Stockland Development Pty Ltd (‘Stockland’). Stockland own the Cloverton landholding within the Lockerbie and Lockerbie North PSP areas, including land iden�fied for the Lockerbie PTC.

113. The submission refers to the retail demand analysis for the two scenarios examined in the EE 2014 Report, and points out that while the full centre network is summarised for Scenario 1 (‘LTC only’) in Table 4.13 of the 2014 Report, no such network summary is presented for Scenario 2. The conclusion is reached that the recommended centre hierarchy involved the lower retail provision of 33,000sqm.

114. In my opinion this ignores the following important aspects of the 2014 Report:

§ EE specifically examined the poten�al for a DDS to be located within the PSP area. § On a broad store provision ra�o EE conclude that the size of the PSP residen�al

popula�on would support one DDS. § When examined in detail, the DDS capacity analysis iden�fies poten�al for a DDS

and states that it would be prudent to plan for a centre to accommodate a DDS. § The centre network summarised in Table 4.13 included only 12,100sqm of

supermarket floorspace when the demand analysis iden�fied poten�al for up to 17,000sqm.

§ Analysis in Sec�on 4.10 specifically incorporates more significant retail provision for Centre C and Centre D to accommodate addi�onal supermarket floorspace and the inclusion of a DDS.

§ Although the full centre network is not summarised therea�er, it could be calculated by adding the addi�onal floorspace at centres C and D (as per Table 4.15) to the centre floorspace for the remaining centres that are unchanged.

115. The submission states that the 2015 Advice did not include any addi�onal retail-economic analysis to jus�fy the dra� FUS, and therefore the 2015 Advice does not conclusively jus�fy “why the larger floorspace provision of 45,000sqm is the favoured op�on for the Donnybrook-Woodstock PSP” (Submission 13, p2). This point is accompanied by a table which compares the terminology and floorspace alloca�ons for each centre in the 2014 Report against those adopted in the exhibited PSP.

116. In rela�on to the jus�fica�on for the larger floorspace, in my opinion this has been adequately provided in the 2014 Report for the reasons I have provided in paragraph 114 above. In par�cular, the 2014 Report concludes that there is support for a DDS to serve the PSP popula�on, and more significant total retail floorspace can be supported across the PSP if one of the centres accommodates a DDS to support a sub-regional shopping role.


117. Also relevant is that the total residen�al popula�on living within the PSP is likely to be substan�ally higher than that used as the basis for the EE analysis of retail poten�al, which adopted the ‘Medium’ popula�on scenario. A larger popula�on base would lead to an increase in supportable retail provision and would assist in substan�a�ng the need for a DDS to be accommodated in one of the LTCs.

118. In rela�on to the informa�on presented in the table accompanying the submission, I note that the total retail floorspace provision in the exhibited PSP is 45,500sqm, which is almost exactly equivalent to the amount of floorspace supported in the 2014 Report under Scenario 2.

119. Some change in floorspace distribu�on has occurred. For example, an increase in retail floorspace at LCC2 has been made, from 1,500sqm in the 2014 Report to 2,500sqm in the exhibited PSP. However, this responds to a recommenda�on in the 2014 Advice to increase floorspace provision because of greater residen�al densi�es close to the sta�on.

120. I have already noted that this centre was iden�fied as a small LTC in the 2014 Report, although this was accompanied by the comment that this centre will either be classified as an LTC or LCC, with the classifica�on depending on the extent and range of alterna�ve uses planned for this centre (eg community facili�es).

121. A small increase has also been made for LTC4, from 1,500sqm to 2,000sqm. In my opinion this is an insignificant adjustment that would have no effect on the centre network.

122. The exhibited PSP includes a number of new LLCs. On this ma�er, I acknowledge the commentary provided in the 2014 Report, highligh�ng the difficulty in establishing viable local convenience facili�es and concluding that these centres need to be planned with flexibility in mind. In my opinion this commentary concedes that not all LCCs will be able to establish retail floorspace to the full poten�al provided as-of-right in the relevant UGZ schedule.

123. Submission 13’s final relevant point is that “the increase in LTC1 to 21,500sqm will foreseeably have a nega�ve impact on the development of retail uses in Lockerbie PTC, par�cularly if LTC2 (sic) develops prior to Lockerbie PTC” (p3).

124. Analysis and commentary on this ma�er is provided in Sec�on 6.


6. ASSESSMENT OF AM GC28

125. This sec�on of my report provides an independent analysis of the need and opportunity for new retail centres within the PSP area to serve the needs of local residents. In undertaking this assessment, I have also examined the opportunity for new supermarket and DDS provision to serve residents within the PSP and in the Northern Quarries PSP area which also falls within the wider catchment.

126. Response to ma�ers raised by Submission 13 is also provided where relevant.

6.1 Retail demand analysis

127. A simplified analysis of total retail demand is presented below, based on the following steps:

§ Calculate total dwelling yield from available NDA and minimum densi�es § Calculate popula�on outcomes by applying an appropriate average household size § Iden�fy relevant core catchments for each planned supermarket-based centre § Calculate total retail demand across the PSP and for each centre catchment by

applying a typical average per capita floorspace provision rate § Assess the planned floorspace provision in each centre against total retail demand

within each catchment in the context of the typical share of retail provision captured by neighbourhood and sub-regional centres.

Lot/dwelling outcomes

128. I have calculated the total number of dwellings likely to be produced within the PSP area by:

§ Tracing over the areas marked in the exhibited PSP as ‘residen�al’ and breaking down into smaller ‘blocks’

§ Crea�ng 500m and 800m buffers from Donnybrook Sta�on and the proposed Lockerbie Sta�on, and 400m buffers around LTC ‘retail’ parcels

§ Using these buffers to assign relevant minimum densi�es to the residen�al land blocks

§ Calcula�ng total dwelling yield by mul�plying the residen�al land area by the relevant minimum density.

129. I have separately calculated the poten�al dwelling yield from the Northern Quarries PSP area by applying a development efficiency rate of 75% to the gross area of 253ha and mul�plying by an average 15 lots per hectare.

130. My analysis is summarised in Table 5 which indicates that the PSP area will accommodate approximately 16,025 dwellings at an overall density of 16 dwelling per net developable hectare. With the inclusion of Northern Quarries, the total residen�al yield is forecast to be 18,870 dwellings.


Table 5: Dwelling yield by density type


Popula�on outcomes

131. At capacity I es�mate that the PSP would accommodate a popula�on of approximately 48,275 persons, with another 8,825 persons living within the Northern Quarries PSP (refer Table 6).

132. These forecasts apply an average household size of 3.1 persons per household (‘PPH’) for tradi�onal detached housing but a lower average household size of 2.9 PPH for land subject to a minimum 18 lots/ha and 2.7 PPH for land within 400m of a sta�on where a minimum 25 lots/ha will be applied. The overall average household size would be approximately 3.0 PPH across the PSP and the wider catchment.

133. My assump�ons on average household size are supported by the evidence in exis�ng growth areas which shows that average household size almost always exceeds 3.0 PPH and is o�en higher than 3.4 PPH. This is illustrated in Figure 6 which displays varia�ons in average size of households in Melbourne’s growth areas using data from the ABS Census 2011. I note that the relevant Forecast.Id projec�ons for the Donnybrook Sub-region predicts that the average household size will be 3.14 persons per dwelling in 2036.

134. A lower popula�on forecast has also been presented where average household size is reduced to 2.7 PPH overall, leading to a total popula�on of 43,465 persons in the PSP and another 7,970 people living in Northern Quarries. However, my opinion is that the High scenario should be used in assessing retail demand and town centre development.

Table 6: Forecast popula�on outcomes

Location NDA (ha)

Density (lots/ha)

Lot / dwelling yield (lots)

Within PSPWithin 500m of a station 46.4 25 1,159Within 500-800m of a station 49.8 18 896Within 400m of an LTC 210.1 18 3,781Remainder 679.2 15 10,187Sub-total within PSP 985.4 16 16,023Northern Quarries 189.8 15 2,846

Total 1,175 16 18,870

Location Dwellings PPH Persons PPH Persons

Within PSPWithin 500m of a station 1,159 2.4 2,780 2.7 3,130Within 500-800m of a station 896 2.6 2,330 2.9 2,600Within 400m of an LTC 3,781 2.6 9,830 2.9 10,965Remainder 10,187 2.8 28,525 3.1 31,580Sub-total within PSP 16,023 2.7 43,465 3.0 48,275Northern Quarries 2,846 2.8 7,970 3.1 8,825

Total 18,870 2.7 51,435 3.0 57,100

Low High


Figure 6: Varia�on in average household size, selected growth areas

Source: Deep End Services; ABS Census 2011


Town centre catchments

135. Core catchments for each of the centres planned to contain a supermarket have been defined as shown in Figure 7, based on examina�on of the road network and judgement as to which centre will be the most convenient for weekly grocery shopping. These should therefore be seen as relevant core catchments for the supermarket component of each centre, rather than for the proposed higher-order role of LTC1.

136. The residen�al area in the northern part of the PSP has not been assigned to a supermarket catchment, reflec�ng its distance from any planned centre and uncertainty about the future road connec�ons that may provide access to centres outside the PSP (such as Lockerbie North).

137. The results of this analysis are summarised in Table 7 which shows that LTC1 will serve the largest catchment containing up to 18,345 residents.

138. The LTC2 core catchment is forecast to contain close to 10,000 residents; however, this centre would also be an important shopping op�on for people living in the Northern Quarries PSP area (8,825 persons).

Table 7: Forecast popula�on at capacity by catchment


Centre catchment Lots Population low Population highWithin PSPLTC1 5,988 16,550 18,345LTC2 3,151 8,610 9,560LTC3 2,617 6,840 7,625LTC4 2,154 5,840 6,485LCC2 1,198 3,060 3,420Remainder PSP 916 2,565 2,840Sub-total PSP 16,023 43,465 48,275Northern Quarries 2,846 7,970 8,825Total 18,870 51,435 57,100


Figure 7: Core centre catchments


Retail floorspace demand

139. I forecast that total retail floorspace demand across the PSP will be approximately 113,500sqm when the popula�on capacity is reached.

140. This forecast is based on an average retail floorspace provision rate of 2.5 sqm per person, which is the figure adopted in the 2014 Report (refer EE, p40). In my opinion this is an appropriate figure having regard to the following:

§ Data from the last Retail Census (1991/2) showed average provision in Melbourne of approximately 2.1 sqm/cap

§ The emergence of larger retail formats has occurred since then (including large format retail or bulky goods, larger supermarkets, etc)

§ Recent detailed measurements prepared by Deep End Services for the NSW Department of Planning have recorded total retail floorspace of approximately 10.9


million sqm in 2015 at an average provision rate of 2.37 sqm/cap, with this forecast to increase to 2.6 sqm/cap by 2036

§ The general consensus is that average retail provision is higher in Melbourne because of fewer land constraints and lower commercial property values

§ There should be recogni�on that a propor�on of total retail provision is supported by transient visitors rather than residents within the metropolitan region.

141. Table 8 summarises my forecasts across the PSP and for the individual core catchments, and includes informa�on on the planned delivery of floorspace as proposed by the PSP.

142. The analysis shows that the total aggregate floorspace to be provided in the PSP (46,000sqm) represents 40% of the demand generated by residents within the PSP and 34% of total demand when the residen�al component of Northern Quarries is included.

143. The distribu�on of retail floorspace by centre type varies considerably depending on the components of centres, their posi�on with respect to catchments and other factors. In my experience on the basis of various assessments, the typical ranges are as follows:

§ Regional centres (PTCs, CADs) 15-20% § Sub-regional centres (MTCs, MACs) 20-25% § Neighbourhood/local (LTCs, LCCs) 25-35% § Large format 25-30%.

144. With a centres network that comprises a number of neighbourhood and local centres serving surrounding communi�es, as well as one centre with a sub-regional role but no large format provision, the provision of 46,000sqm of retail floorspace can be summarised by type and share of total demand as follows:

§ Sub-regional (LTC1) 21,500sqm (19% of total PSP demand) § Neighbourhood/local (remaining) 24,500sqm (22% of total PSP demand)

145. The provision rates set out above are at the lower end of the typical demand ranges and therefore appear supportable in terms of overall floorspace provision and by type.

Table 8: Forecast retail floorspace demand by catchment


Centre catchment Population Average sqm per capita

Total retail demand sqm

PSP proposed sqm

PSP share of total demand

Within PSPLTC1 18,345 2.5 45,860 21,500 46.9%LTC2 9,560 2.5 23,900 10,000 41.8%LTC3 7,625 2.5 19,060 4,500 23.6%LTC4 6,485 2.5 16,210 2,000 12.3%LCC2 3,420 2.5 8,550 2,500 29.2%Other LCCs 2,840 2.5 7,100 5,500 77.5%Sub-total PSP 48,275 2.5 113,580 46,000 40.5%Northern Quarries 8,825 2.5 22,060 - -Total 57,100 2.5 135,640 46,000 33.9%


6.2 Supermarket floorspace demand

146. The demand for supermarket floorspace can also be assessed by applying a typical average floorspace provision rate to the popula�on base within the PSP and the Northern Quarries PSP area.

147. I have examined the average supermarket floorspace provision rate across Melbourne in order to determine an appropriate average to apply in these calcula�ons. My analysis is presented in Figure 8 which illustrates the varia�on in average supermarket floorspace provision for each metropolitan local government area.

148. The chart demonstrates that outer LGAs have an average provision rate of 0.35 sqm/cap, which is higher than those in middle (0.29 sqm/cap) or inner (0.24 sqm/cap) LGAs.

149. I have adopted an average provision rate of 0.38 sqm/cap. This represents the average for outer LGAs excluding Nillumbik which has par�cularly low supermarket provision reflec�ng the spa�al distribu�on of its popula�on. I have not incorporated any growth in average provision rates over �me.

150. On the basis of the above, the PSP popula�on would support approximately 18,345sqm of supermarket floorspace, with another 3,354sqm supported by people living within the Northern Quarries PSP area, as shown in Table 9.

151. The analysis shows that overall the proposed supermarket floorspace under Am GC28 (17,000sqm) is broadly in balance with total forecast demand, with the following commentary provided for selected centres:

§ Supermarket provision at LTC1 is significantly below the forecast demand, but the catchment has been drawn generously to the north where some residents may choose to travel south via Pa�erson Drive to LTC2. LTC1 would also be a significant shopping op�on for people living in the LTC4 catchment.

§ Supermarket provision at LTC2 is above the forecast demand, but this centre will have an important role as the closest convenient supermarket-based centre for most of the residen�al part of Northern Quarries PSP area, and could also draw people living in the area north of Greens Gully Road. I es�mate that the total catchment popula�on for LTC2 would be close to 14,000 persons, which would support the 5,000sqm of supermarket floorspace proposed under the PSP.

§ Supermarket provision at LTC4 is below the es�mated demand, but this does not account for the proximity of LTC1 and its role in providing grocery and higher-order shopping for people in the LTC4 catchment.

§ LCC2 is planned to accommodate supermarket floorspace in excess of forecast demand, however this centre is well-located adjacent to an exis�ng railway sta�on and will be able to trade from people using the sta�on as well as workers in the surrounding commercial areas and employment precincts.


152. Overall this analysis confirms that the proposed distribu�on of supermarkets is appropriate to serve the PSP. I note that it also suggests that a small or mid-sized supermarket could be supported in the Northern Quarries PSP area, subject to further analysis during the PSP prepara�on.

Table 9: Forecast supermarket floorspace demand


153. In addi�on to the analysis provided above, I have included informa�on on the typical supermarket provision rate measured in terms of the number of people per store for each LGA in metropolitan Melbourne. This analysis, presented in Figure 9, shows that outer LGAs have an average of one supermarket for approximately every 7,200 residents, with a higher provision rate (ie more persons per supermarket) occurring in middle and inner LGAs.

154. With a popula�on of up to 57,000 residents at full capacity, these provision rates suggest that up to 8 supermarkets (including smaller, mid-sized and full-line stores) could be provided across the PSP and including future provision within the Northern Quarries PSP area.

155. The exhibited PSP allows for 8 supermarkets in total, although this includes one proposed for the Merri-stock LCC which has a small catchment that is unlikely to support any form of supermarket provision. My recommenda�on would be to delete reference to a supermarket at this centre and consider planning for a mid-sized store within the Northern Quarries PSP.

Centre catchment Population forecast

Average sqm per capita

Total smkt demand sqm

PSP proposed sqm

PSP share of total demand

Within PSPLTC1 18,345 0.38 6,971 5,500 78.9%LTC2 9,560 0.38 3,633 5,000 137.6%LTC3 7,625 0.38 2,898 2,500 86.3%LTC4 6,485 0.38 2,464 1,500 60.9%LCC2 3,420 0.38 1,300 1,500 115.4%Other LCCs 2,840 0.38 1,079 1,000 92.7%Total 48,275 0.38 18,345 17,000 92.7%Northern Quarries 8,825 0.38 3,354 - -Total 57,100 0.38 21,698 17,000 78.3%


Figure 8: Average supermarket floorspace provision rate 2016


0.00 0.05 0.10 0.15 0.20 0.25 0.30 0.35 0.40 0.45 0.50

Yarra (C)Stonnington (C)

Port Phillip (C)Bayside (C)

Melbourne (C)Glen Eira (C)

Moonee Valley (C)Kingston (C)

Brimbank (C)Maribyrnong (C)

Whitehorse (C)Banyule (C)

Manningham (C)Darebin (C)Monash (C)

Moreland (C)Hobsons Bay (C)

Greater Dandenong (C)Boroondara (C)

Cardinia (S)Mornington Peninsula (S)

Knox (C)Whittlesea (C)

Yarra Ranges (S)Hume (C)

Wyndham (C)Casey (C)

Frankston (C)Maroondah (C)

Melton (C)Nillumbik (S)

Inne

rM

iddl

eO

uter

Sqm per capita

Average 0.35 sqm/cap




Figure 9: Supermarket store provision rate 2016


0 2,000 4,000 6,000 8,000 10,000 12,000 14,000

Glen Eira (C)Yarra (C)

Port Phillip (C)Stonnington (C)

Bayside (C)Melbourne (C)

Monash (C)Greater Dandenong (C)

Whitehorse (C)Boroondara (C)

Manningham (C)Moreland (C)Brimbank (C)Kingston (C)Darebin (C)

Hobsons Bay (C)Banyule (C)

Moonee Valley (C)Maribyrnong (C)

Nillumbik (S)Melton (C)

Frankston (C)Hume (C)Casey (C)

Wyndham (C)Maroondah (C)Whittlesea (C)

Knox (C)Cardinia (S)

Yarra Ranges (S)Mornington Peninsula (S)

Inne

rM

iddl

eO

uter

Persons per store

Average 7,185 persons / store




6.3 DDS floorspace demand

156. I have prepared a similar exercise to assess the opportunity to accommodate a DDS within the PSP area (refer Table 10).

157. Figure 10 shows that the average DDS floorspace provision rate across outer LGAs in Melbourne is approximately 0.18 sqm/cap, higher than the provision rates in middle (0.16 sqm/cap) and inner (0.07 sqm/cap) LGAs.

158. Applying this average provision rate, total demand for DDS floorspace generated by PSP residents would be 8,690sqm. Within the inclusion of the Northern Quarries popula�on, total demand is forecast to be 9,260sqm.

159. I have also forecast the DDS floorspace demand for a ‘Core DDS catchment’ relevant for LTC1 which has been defined as the area of the PSP east of Pa�erson Drive, plus the inclusion of the Northern Quarries PSP area.

160. The Core DDS catchment would have a capacity popula�on of approximately 39,470 persons and would generate demand for approximately 7,100sqm of DDS floorspace.

161. This analysis provides strong support for the accommoda�on of a DDS within LTC1 as proposed in the PSP.

Table 10: Forecast DDS floorspace demand


162. Figure 11 presents informa�on on the average DDS store provision measured in terms of persons per store, showing that the typical provision ra�o in outer LGAs is one store per 36,470 persons. With a total popula�on base of up to 51,435 residents living within the PSP and in the Northern Quarries area, a DDS is required to serve this community on typical provision rates.

PSP catchment Population forecast

Average DDSsqm per capita

Total DDS demand sqm

Within PSP 48,275 0.18 8,690plus Northern Quarries 51,435 0.18 9,260Core DDS catchment 39,470 0.18 7,105Proposed sqm 7,000Share of demand 80.6%


Figure 10: Average DDS floorspace provision rate 2016


0.00 0.10 0.20 0.30 0.40

Stonnington (C)

Melbourne (C)

Yarra (C)

Glen Eira (C)

Bayside (C)

Port Phillip (C)

Maribyrnong (C)

Whitehorse (C)

Manningham (C)

Brimbank (C)

Moonee Valley (C)

Greater Dandenong (C)

Kingston (C)

Banyule (C)

Darebin (C)

Hobsons Bay (C)

Monash (C)

Boroondara (C)

Moreland (C)

Hume (C)

Frankston (C)

Knox (C)

Maroondah (C)

Wyndham (C)

Casey (C)

Mornington Peninsula (S)

Melton (C)

Whittlesea (C)

Yarra Ranges (S)

Cardinia (S)

Nillumbik (S)

Inne

rM

iddl

eO

uter

Sqm per cap





Figure 11: DDS store provision rate 2016


147,821

92,060

177,221

170,389

63,542

0 20,000 40,000 60,000

Glen Eira (C)

Yarra (C)

Melbourne (C)

Stonnington (C)

Bayside (C)

Port Phillip (C)

Boroondara (C)

Moreland (C)

Banyule (C)

Monash (C)

Hobsons Bay (C)

Manningham (C)

Brimbank (C)

Kingston (C)

Greater Dandenong (C)

Darebin (C)

Moonee Valley (C)

Whitehorse (C)

Maribyrnong (C)

Yarra Ranges (S)

Cardinia (S)

Casey (C)

Whittlesea (C)

Maroondah (C)

Wyndham (C)

Melton (C)

Mornington Peninsula (S)

Knox (C)

Frankston (C)

Hume (C)

Nillumbik (S)

Inne

rM

iddl

eO

uter

Persons per DDS





6.4 Effect on Lockerbie

163. Submission 13 contends that the eleva�on of LTC1 to include a DDS with total retail floorspace of 21,500sqm would have an adverse impact on the ability for Lockerbie PTC to secure a regional retail role as planned, par�cularly if LTC1 were to develop ahead of Lockerbie PTC.

164. The retail role of Lockerbie will be underpinned by popula�on growth projected to occur throughout the whole of the Northern Growth Corridor. This region will ul�mately accommodate a regional popula�on of 260,000 to 330,000 according to the Melbourne North Growth Corridor Plan (‘NGCP’) and as summarised in the PSP Background Report.

165. Lockerbie PTC’s planned retail provision of 80,000sqm reflects the role it will play as a significant shopping des�na�on within this region. At full development Lockerbie PTC is planned to accommodate department store(s), discount department stores, supermarkets, specialty retailing and large format retailing, as well as a wide range of non-retail business and community func�ons.

166. Total projected retail demand by residents within the NGCP region is broadly forecast to be approximately 650,000sqm to 825,000sqm if average demand rates of 2.5 sqm/cap are applied.

167. The implica�on is that in order to enable Lockerbie PTC to develop the 80,000sqm of retail floorspace planned for the centre, it will need to capture approximately 10-12% of total demand generated across the NGCP region. This is below the 15-20% of retail demand typically captured by regional centres.

168. Total demand for DDS floorspace is es�mated at approximately 47,000sqm to 60,000sqm across the NGCP region when full development is reached. This would be sufficient to support at least 7 and possibly up to 9 stores (depending on size) located in centres throughout the region. As many as 30-40 supermarkets of various sizes would be supported in the region at typical provision rates.

169. It will be important for Lockerbie PTC to secure interest from the major supermarket and DDS operators in order to develop the key anchors necessary to establish its weekly grocery role and subsequently its higher-order shopping role.

170. The centre will become an a�rac�ve loca�on for supermarket development as residen�al construc�on proceeds within the Lockerbie PSP, with addi�onal supermarket development poten�al (2nd and 3rd supermarkets) becoming viable as Lockerbie North and Donnybrook / Woodstock PSP are developed. This reflects the advice given by Urbis to Stockland in October 2011 and is unaffected by the proposed centres planned within the Donnybrook / Woodstock PSP area.


171. Lockerbie PTC will also be the favoured loca�on at which to establish a DDS because it represents the most central posi�on with respect to the major residen�al development fronts that will commence in Lockerbie PSP, Lockerbie North PSP and Donnybrook / Woodstock PSP, as well as future development in Beveridge Central and Beveridge North East PSPs. Moreover, the centre is well situated close to the major arterial roads and highways in the region that will a�ract spending from beyond these PSP areas.

172. I note that construc�on work has already commenced in Lockerbie South, and the likely direc�on of development is from Donnybrook Road northwards having regard to infrastructure servicing. In the future there are likely to be mul�ple growth fronts extending northwards from Donnybrook Road, with the major developers being Stockland, DFC and Mirvac.

173. LTC1 is unlikely to support the provision of DDS shopping un�l the catchment has ‘filled out’ across the Woodstock PSP area (ie the ‘Core DDS catchment’ as defined in Sec�on 6.3 above). In the intervening period, Lockerbie PTC will be the closest available centre at which DDS shopping will be ini�ally provided, and would be expected to secure a major DDS operator well before LTC1 has a catchment of sufficient size to support a DDS.

174. In these circumstances development at LTC1 will have li�le effect on the ability of Lockerbie PTC to secure major DDS brands and establish the centre as the dominant higher-order shopping des�na�on in the region.


7. SUMMARY OF OPINION

175. The retail-economic analysis underpinning Am GC28 is generally sound, and provides an appropriate basis for planning a network of centres to provide local retail and business services to the PSP community.

176. My independent assessment of retail demand across the PSP generally supports the proposed quantum of retail floorspace and the distribu�on across the LTCs and LCCs.

177. I recommend dele�ng the reference to a supermarket at LCC6 and reducing the proposed floorspace to 500sqm.

178. I recommend a change to the centre designa�ons to include LCC2 as a Local Town Centre.

179. The Essen�al Economics 2014 Report provides an appropriate examina�on of the poten�al for one of the LTCs to be elevated to include a DDS, and this is supported by my own independent analysis.

180. LTC1 is an appropriate loca�on at which to accommodate a DDS.

181. LTC1 is unlikely to develop ahead of Lockerbie PTC and will not prevent Lockerbie from a�aining a higher-order regional shopping role.

I have made all the enquiries that I believe are desirable and appropriate and no ma�ers of significance which I regard as relevant have to my knowledge been withheld from the Tribunal.

MATTHEW LEE Principal, Deep End Services 9 May 2016

DFC (Woodstock) – Am GC28 Donnybrook & Woodstock PSP – Economic witness statement – M Lee deep end services pty ltd

A�achment 1: Curriculum vitae for Ma�hew Lee

DFC (Woodstock) – Am GC28 Donnybrook & Woodstock PSP – Economic witness statement – M Lee deep end services pty ltd

A�achment 2: Urbis advice 25 October 2011

MEMO LOCKERBIE STAGING 251011

25 October 2011

Jason Shaw State Planning & Approvals Manager, Vic Stockland Developments [email protected]

Dear Jason,

Stockland Lockerbie Staging & Distribution of Retail Floorspace Options

The purpose of this memo is to provide an opinion on the following:

The optimal distribution of retail floorspace between the Lockerbie Principal Town Centre (PTC) and proposed Local Town Centres (LACs) per the draft Precinct Structure Plan at capacity; and

Indicative staging and timing of development of the PTC and LACs.

The tables and maps used in our analysis referred to below are located at the end of this memo.

Distribution of Floorspace

Our September 2010 report identified that, at capacity, the Lockerbie PTC could account for 80,000 sq.m of shop floorspace. This equates to a 33% share of the total Hume Growth Corridor retail shop floorspace of 242,200 sq.m.

The PTC will contain a full range of retail facilities and serve multiple retail and other functions. The PTC will be highly accessible from all parts of Lockerbie and will serve a local district and regional role for residents. Given the scale and location of the PTC it is recommended that local centres be provided at appropriate locations and scale to provide more localised retailing limited to food and convenience shopping and home services.

The distribution of floorspace and the sustainable size and competition of each centre should reflect the attributes of each location. Key drivers are:

access to the location by road and direct exposure to road traffic

the population capability in a realistic catchment area, including walk/ride, public transport and principally car access

the natural level of activity generated in the location from uses such as a train station, school, employment nodes etc.

MEMO LOCKERBIE STAGING 251011 PAGE 2

competition

the location size of other centres serving each area

the staging of residential and associated retail development

The following table provides comments on the attributes of each proposed LTC in the draft Lockerbie Precinct Structure Plan (labelled in Map 1) and details their expected retail use and supportable floorspace at capacity.


LTC NAME LOCATION ATTRIBUTES EXPECTED USE INDICATIVE RETAIL FLOORSPACE

Northern and Gunns Gully Road centres

The Northern centre is adjacent to main internal arterial road and a primary school and is 1.2km from the PTC retail core by road

Gunns Gully Road is the access point from the Hume Freeway and is 800m from the PTC retail core by road

Supermarket and specialties in one centre and a convenience store and specialties in the other

3,000sq.m and 400sq.m

Donnybrook Station

Adjacent to railway station

3km from the PTC retail core by road

Take-away food 500 sq.m

Southern centre Adjacent to main North-South arterial road and primary school

2.4km from the PTC retail core by road

Supermarket and specialties

5,000 sq.m

Western Adjacent to primary school and local connector street (lack of exposure to main roads)

1km from the PTC retail core by road

Convenience store /milk bar and take-away food

400 sq.m

Total LTC Retail Floorspace 9,300 sq.m

As shown in Map 1 and the table above, some of the proposed LACs are in very close proximity to the PTC retail core or have other locational attributes which may compromise their sustainability and viability.

Given the regional nature, relative size and broader range of retail and other activities of the PTC at capacity, the LTCs will need to compete on their superior convenience and accessibility/walkability for the more immediate local catchments they serve, which include the residential population, school staff and students and railway commuters.

Staging and Timing

Based on the breakdown of lots provided in the Stockland Development Staging June 2011 document, we have adjusted our September 2010 population forecast shown in Table 1. This revision has the effect of pushing population growth in the Primary Lockerbie sector one year later, while the total population of the region at capacity does not change.

Refer to Map 2 for indicative timing of housing developments.

Accordingly, Table 2 details our expected staging and timing of each stage of development of the PTC, and timing of the LACs.


There are two options that can be pursued in the early development of retail amenities in the Lockerbie PSP area. However, after 2025 the rest of the timing and staging of the retail developments within the Lockerbie PSP area converge into a single path.

2020

Option 1 involves early development of the PTC in order to secure the greatest likelihood of the centre developing as the primary and largest centre in the new growth corridor. At a population threshold of 5,000 in 2020 for the Lockerbie PSP area, the first stage of development of the PTC incorporating the first supermarket and shops designed to serve more of a food retail and convenience function can commence operation. This would include non-retail shops such as real estate and banks. The timing of this stage will principally depend on the population of the Lockerbie estate itself rather than the broader corridor population as the centre will serve a localised food and convenience function at this stage.

Option 2 involves development of a supermarket based centre up to 3,000 sq.m in the northern part of the Lockerbie PSP (potentially at Gunns Gully Road or the designated Northern LTC in the Lockerbie PSP) anchoring some food retail and take-away food shops first. Similar to Option 1, this development is appropriate when a population threshold of 5,000 people in the Lockerbie PSP area is reached.

On one hand, locating retail amenities at the northern part of the estate would make the offer accessible to more people early on (residential development to commence in the north and residents outside the estate), and the development can occur earlier than the PTC Stage 1. On the other hand, this option can delay the development of the PTC and may reduce the retail floorspace capacity in the PTC. The exact location of this supermarket based centre (either in the Northern centre or Gunns Gully Road centre) should be determined by the developer based on market potential and commercial influences at that time.

2025

By 2025, if Option 1 is pursued in 2020 and the population in the Lockerbie estate reaches close to 20,000 people and close to 85,000 in the total region, Stage 2 of the PTC retail core and associated bulky good/homemaker precinct can be developed. This stage would involve adding a second supermarket and first discount department store, extending core retail floorspace to 20,000 sq.m. The centre would be of a sufficient scale to serve a sub-regional population.

It is appropriate at this point for the petrol station with a convenience store and take-away shops in the Gunns Gully Road LTC to follow. However should a petrol station eventuate at Gunns Gully Road LTC, this centre could be developed earlier.

If Option 2 is pursued in 2020, the first stage of development of the PTC incorporating the first supermarket and shops designed to serve more of a food retail and convenience function can commence operation.

A convenience store or milk bar and take-way shops in the Western LTC to follow housing development could also be developed under both options, however we stress that we have assumed the state primary school to open in line with the pattern of housing development, and should there be delays in the opening of the primary school, the retail should also be delayed.


2030

By 2030, Stage 3 of the PTC can proceed when the trade area population reaches some 85,000 people, extending the core retail floorspace to 35,000 sq.m and adding a second discount department store, mini majors and a broader provision of specialty shops. This scale of centre would clearly serve a retail role for the corridor as a whole and would be the largest centre in the corridor at this time.

2035

By 2035 when the trade area population exceeds 100,000 people the retail offer in the PTC could further extend to include a third supermarket, additional mini majors and possibly cinemas. The centre would be cementing its place as a genuine regional facility, supported by an extensive provision of bulky goods. The pattern of remaining areas to develop in Lockerbie suggests that there would be capacity in the market to develop the remaining three LACs:

We would recommend only a limited number of shops say 500 sq.m (take-away food and services) at the Donnybrook Station LTC given its railway station location and thus proximity to the commuter market that will be using Donnybrook Road to access the station. Although we understand that the Stockland residential developments surrounding Donnybrook Station are planned to be completed after 2038 or later, the existing station serves commuters from Kalkallo township and in future can serve commuters not just from the Lockerbie development but from the adjacent large MAB Merrifield development to the west.

There is likely to be room in the market to support an additional full line supermarket anchoring some shops (~5,000 sq.m retail) at the Southern LTC by 2035 that can serve both the southern end of the estate and Kalkallo residents to the west. This centre is also sufficiently far (2.4 km) from the PTC to be viable. This centre could also include non-retail community/health facilities such as gym/sporting facilities, particularly given the active open space adjacent to the site.

Finally, the last stage of development for the PTC at capacity could incorporate the addition of a department store and associated higher order retailing if the trade area population reaches at least 190,000 people, to cement its regional role as the pre-eminent retail destination.

We trust this letter meets your immediate requirements. Please do not hesitate to contact the writer or Princess Ventura should you require further assistance. Yours sincerely,

Simon Rumbold Director - Property Economics


Map 1 Draft Lockerbie PSP with LACs labelled


Map 2 Draft Lockerbie PSP Development Staging


Updated Population ForecastSTOCKLAND LOCKERBIE AND WIDER REGION TABLE 1

2020 2025 2030 2035 CapacityPrimary Lockerbie 5,300 12,400 19,800 27,300 35,000Urban Corridor 12,700 30,600 48,800 68,300 145,300Total Region 42,200 63,200 84,900 108,000 190,300Average Annual Growth (No.) 2020-25 2025-30 2030-35Primary Lockerbie 1,420 1,480 1,500Urban Corridor 3,580 3,640 3,900Total Region 4,200 4,340 4,620Average Annual Growth (%) 2020-25 2025-30 2030-35Primary Lockerbie 18.5% 9.8% 6.6%Urban Corridor 19.2% 9.8% 7.0%Total Region 8.4% 6.1% 4.9%Source : Urbis


Lockerbie Activity Centres Scale, Staging & Timing TABLE 2

Year

2025 Gunns Gully Road LTC

Petrol station, convenience store & specialties 350 convenience store 150 take-away food 400 total centre

OPTION 1

Northern and Gunns Gully Road LTCs

Supermarket & specialties2,500 majors 500 food retail & catering3,000 total centre

Convenience store & specialties 350 convenience store 150 take-away food 400 total centre

PTC Stage 1

Supermarket & specialties4,000 majors2,000 mini majors6,000 core retail1,000 non-retail shopfront7,000 total shopfront4,000 bulky & showrooms11,000 total centre

OPTION 2

2020 PTC Stage 1

Supermarket & specialties4,000 majors2,000 mini majors6,000 core retail1,000 non-retail shopfront7,000 total shopfront4,000 bulky & showrooms11,000 total centre

2025 PTC Stage 2

2 supermarkets, DDS & specialties, large hardware15,000 majors 4,000 mini majors & specs19,000 core retail 1,000 non-retail shopfront20,000 total shopfront20,000 bulky & showrooms40,000 total centre

2025 Western LTC Milk bar & take-away 400 retail shopfront

22,000 majors9,000 mini-majors & specs

31,000 core retail4,000 non-retail shopfront

35,000 total shopfront30,000 bulky & showrooms65,000 total centre

23,500 majors13,000 mini-majors & specs36,500 core retail13,500 non-retail shopfront50,000 total shopfront40,000 bulky & showrooms90,000 total centre

2035 Donnybrook Station LTC Take-away food 500 take-away food

2035 Southern LTC Supermarket & shops4,000 1,000 5,000

supermarketspecialtiestotal centre1

44,500 majors20,500 mini-majors & specs65,000 core retail15,000 non-retail shopfront80,000 total shopfront60,000 bulky & showrooms

140,000 total centreSource : Urbis

Capacity PTC Stage 5

Department store, 2-3 discount department stores, 2.5 supermarkets, cinemas, mini-majors, specialty shops

2035 PTC Stage 4

2.5 supermarkets, 2 discount department stores, mini-majors, cinemas, shops

2030 PTC Stage 3

2 supermarkets, 2 discount department stores, mini majors & specialty shops; extended homemaker precinct


Map 3 Lockerbie Principal Town Centre Trade Area