21St October 2016 Ms Anita Allen C/- Department of Planning, Transport

21st October 2016

Ms Anita Allen c/- Department of Planning, Transport and Infrastructure GPO Box 1815 Adelaide SA 5001 [email protected]

Re: SAIR Submission – 30 Year Plan for Greater Adelaide - 2016 Update, Draft for Consultation

South Australian Independent Retailers (SAIR) representing the Foodland and IGA supermarkets are pleased to provide a submission in relation to the update and review of the 30 Year Plan for Greater Adelaide. SA Independent Retailers acts on behalf of Foodland and IGA supermarkets. There are 115 South Australia based owners operating a total of 236 Foodland, IGA and Friendly Grocer supermarkets across the State, currently employing more than 15,000 South Australians In principle, SAIR are supportive of the updated 30 Year Plan and the various policy themes that will guide land uses development in the Greater Adelaide region. The policies that underpin the key theme of Transit Corridors, Growth Areas and Activity Centres are of key importance to our owners and operators. We note with interest the wording of Policy 8 under this theme; namely

P8 Provide retail and other services outside designated activity centres where development will contribute to the principles of accessibility, a transit-focused and connected city, high quality urban design, economic growth and competitiveness

Firstly, it would be useful to have some greater clarity around the wording of this policy, particularly in terms of the size and magnitude of retail development and services that could potentially occur outside of a designated activity centres. We are concerned if this policy resulted in the development of new activity centres outside of existing centre zones in an unplanned or ad-hoc manner as has previously occurred in places such as Renmark, where the result has been a fragmented township and the demise of the town’s main street. There are similar examples in numerous regional towns that we have previously reported.

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‘advocating for all independent owners of Foodland; IGA and Friendly Grocer supermarkets in South Australia’ PO BOX 2176, KENT TOWN SA 5071 | M: 0413 282 641 | E: [email protected] | ABN: 82 804 971 951

As we have stated previously, there is real risk to the viability of existing centres and in particular regional townships, if new retail developments are allowed to be developed, away from, or far removed, from existing centre zones.

If new retail development is going to be allowed to occur outside of existing activity centres, we propose that it should only occur where;

1. A current centre zone is already fully developed i.e. the centre zone is at capacity; and 2. Adjacent land or land immediately abutting or across the road from the existing activity has been unable to be acquired or developed i.e. some form of linear or like expansion of the existing centre was not possible.

Given the current retail climate and challenges facing the retail supermarket sector in South Australia, we would also suggest an audit and analysis of current turnover and tenancy occupancy rates for all existing centres in order to form a baseline position. These figures should then be analysed first to ascertain if there is in fact a need for more retail floor space development prior to enabling new centres to develop outside of the existing activity centres. Dependent upon these results it may be that retail development can be accommodated outside of the existing centre zones, if the above two (2) scenarios (listed above) cannot be achieved, particularly if there is over trading in a specific locality and there are little or no tenancy vacancies in existing activity centres.

In short, it is vital that existing activity centres or centre zones are fully developed and any expansion or abutting development opportunity fully explored first, before new activity centres are allowed to be develop outside of designated activity centres.

Thank you again for the opportunity to comment on this update of the 30 Year Plan, we support it, on the basis that it does not create an uneven playing field by allowing the premature development of comparable scale new retail developments outside of existing activity centres without first exploring the expansion of these existing centres and centre zones and ensuring the existing retail locality can accommodate the new retail development in a centre trading context. We would encourage you to consider the expansion criteria and centre audit proposal referred to above as part of your policy with respect to the development of new retail development outside of existing designated activity centres. If you have any questions, or wish to clarify any aspects of this submission, please do not hesitate to contact the undersigned or feel free to contact our planning adviser Ms Amanda Price-McGregor on 0406 124 977. Yours sincerely

Colin Shearing Graham Ingerson Chief Executive Officer Government Relations Adviser

cc Steven Copus

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