30 March 2017 Greater Sydney Commission Draft District Plans PO Box 257 Parramatta NSW 2124 Dear Sir/Madam, This submission has been made on behalf of Scentre Group Limited (Scentre Group) and in response to the public exhibition of the above three (3) Draft District Plans (DDPs) and its companion document Towards our Greater Sydney 2056 (TGS). Scentre Group was created on 30 June 2014 through the merger of Westfield Retail Trust and interests of each of these entities in Australia and New Zealand with retail real estate assets under management valued at $45.7 billion and shopping centre ownership interests valued at $32.3 billion. Each of these shopping centres operated under the Westfield brand and are an essential part of the In 2016, over 525 million customers visited a Westfield shopping centre, spending more than $22 billion across the Australian and New Zealand Portfolio of 39 shopping centres. Thirteen (13) of these centres, or 33% of its current portfolio is located within Metropolitan Sydney, its largest market. Given this market presence within Sydney, Scentre Group has a long history of participation and engagement in land use planning matters that affect its property and business interests and again is pleased to be making this submission. The table overleaf provides a summary of the town planning status of all Westfield Shopping Centres throughout Sydney. It provides current zoning as well as a comparison of the centre designation within which each shopping centre is located under both the 2014 Metropolitan Strategy and latest DDP. Notably: SA6597_GSC_DDP Submission_SG_FINAL 30.3.17_DH There is at least one Westfield Shopping Centre in every District. This includes 5 wholly owned centres located throughout the 3 Districts subject to this submission Every Westfield shopping centre is located either within a Strategic or District Centre under the DDPs. The permissibility of residential development across the portfolio varies. This point will be discussed further below in this submission. manager of wholly owned; 50% jointly owned (Hurstville, Miranda, Warringah Mall, Liverpool, Parramatta, Mt Druitt, Penrith) or independently owned (Eastgardens) assets. It should be noted that Scentre Group has instructed Urbis to prepare 5 other submissions to the DDPs on behalf of both its respective joint and independent owners of its Westfield shopping centre assets. Furthermore, and in some instances, it is understood that these joint and independent owners are making their own separate submissions to the DDPs. While the DDPs are about managing change, likewise, we are also witnessing the change to the nature of traditional shopping centres. This is reflective of broader global trends as cities become denser and shopping centres, particularly large scale centres such as those within the Scentre Group portfolio, find themselves well positioned respond to these trends due to: Their significant land holdings often the Westfield Shopping Centre represents one of the largest amalgamated land holdings in each of the above centres. Their immediate proximity to mass transit. Eleven (11) out of 13 centres above are within 400m of a train station. In the case of Chatswood and Sydney, these Westfield centres will also have SA6597_GSC_DDP Submission_SG_FINAL 30.3.17_DH 2 walkable access to a metro station within the next 5-10 years. In the case of Westfield Parramatta, there is now early Government announcements over a potential West Metro connecting Parramatta and Sydney CBDs This evolution is graphically represented in the following diagram, summarising key attributes of core Scentre Group assets. Source: Urbis In this context, Scentre Group (and its joint owners) is well positioned to contribute to the productivity and liveability goals of the DDPs by providing for retail led mixed use opportunities of significant scale. This is evident by: The Planning Proposal currently before Georges River Council to rezone Westfield Hurstville B4 Mixed Use to accommodate long term retail (job) growth, a significant communal space tying into the town centre and a mixture of short and long term accommodation above podium level. The Stage 1 DA currently before the City of Sydney seeking retail renewal of the recently acquired David Jones Market Street site with a significant residential tower above. The approval for a 35,000sqm commercial office tower above Westfield Parramatta with potential expand this to over 100,000sqm of commercial floor space. These mixed-use transformations of Scentre Group assets are not unique to Sydney (nor to Scentre Group) and similar mixed-use developments are planned at Westfield Whitford City in WA, Macquarie Centre, Top Ryde and Rouse Hill Town Centre, each in NSW. SA6597_GSC_DDP Submission_SG_FINAL 30.3.17_DH 3 Renderings of the Westfield Hurstville and Whitford City mixed use concepts are included below: Westfield Hurstville Vertical Mixed Use Source: Urbis Westfield Whitford City (WA) Horizontal Mixed Use Source: Urbis SA6597_GSC_DDP Submission_SG_FINAL 30.3.17_DH 4 The key distinguisher for each of these is that retail remains the dominant activity. These are retail-led mixed use transformations, maintaining and expanding their significant employment and broader economic contributions as opposed to those that are residential developer led with a limited retail offer which tend to be the nature of most current mixed-use projects. The Draft District Plans and TGS growth, driven by population increase needs careful guidance and it is considered that generally all documents set an appropriate basis for managing this growth. perspective the following broad observations are made: Investment decisions are typically made over a medium to long term horizon and a strong land Sydney Portfolio. For example, Scentre Group recently disposed of its former North Rocks centre. That centre has no strategic designation under the DDPs. The DDPs and TGS provide a sound basis for investment by building on the strength based on a network of well-connected centres. Similarly, Scentre Group strongly supports the release of the TGS document which provides a basis to consider the investment in potential new shopping centre locations required to support the growth of Western Sydney. Scentre Group acknowledges that this document will form the basis of an updated Metropolitan Planning Strategy to be released later in 2017. It is assumed that this pending document will better integrate transport planning and investment to support the identification of potential new planned centres. In the short to medium term, development decisions are informed by the way land use policy is consistently applied and by the way it is translated into statutory local environmental plans. For effective private sector investment, the GSC and Councils needs to be careful in how it plans and implements uplift to cater for growth to avoid passive site owners simply enjoying planning gain with resultant increases in land value. The focus for planning implementation must be on mechanisms that deliver public benefit as well as private investment returns to those who are taking the risk of implementing the intent of planning policy. It is felt that the DDPs are potentially open to inconsistent application at present, and need to be supported by more detailed policy guidance, particularly around retail investment. Furthermore, the graphical diagrams for each of the Centres contained in the DDPs present a somewhat underwhelming perspective of simply articulating the existing situation without giving any real direction for growth. The DPPs are an opportunity to better frame the strategic potential of each centre to guide Council more detailed local strategic planning work in a much more aligned manner. (This is discussed in further detail below). In this respect, retail is playing a growing role both in absolute numbers and as a proportion of total employment within Sydney as evident by the table below. SA6597_GSC_DDP Submission_SG_FINAL 30.3.17_DH 5 Linked with the spatial concentration of retail jobs within centres, reinforces the need to support the DDPs with a clear retail investment policy that provides transparent and consistent guidance to all parties wishing to invest in retail activities. There is a pressing need to support the DDPs implementation with a transparent retail policy that complements the DDP urban structure based on the proposed hierarchy of centres. The DDPs refer to a retail floor space data set however this is not yet publicly available and makes it difficult to understand the basis for the statements about current retail provision across the districts and its breakdown between discretionary and non-discretionary retail floor-space. In the absence of both, the productivity priorities around planning for new centres cannot be advanced with any certainty and leaves open the potential for ad hoc and unplanned development. This can place unnecessary strain on infrastructure, not to mention undermines the opportunity for building vibrancy and critical consumer mass around planned centres and collaboration areas, discussed further below. considerable merit however appears to be limiting insofar as the definition appears to place caveats on the opportunities for private sector involvement. These collaboration areas are typically associated with Strategic Centres, e.g. Penrith and Liverpool and the Randwick Health and Education Super-Precinct. Best practice planning suggests that the best urban outcomes occur when there is alignment between public and