City of Charles Sturt 21. DAP Report 15/07/15

ATTACHMENT A

[Attachment A consists of 4 pages]

DEVELOPMENT PLAN PROVISIONS - CONSOLIDATED 15 May 2014

Local Centre Zone

Objective 1 A centre acconinodating sm --cate convenience slopping, office, service, mecical and conwminaty Complies facthbes to serve the day-to-day needs of tie local oonwruity

PDC 1 1 The kllowing bnns of development are envisaged in the zone: Complies •advertisernierit • corrwmsuty facility - - room • rr.nh-mert • oThce • office and dling • shop • shop and dweIIi rig

GENERAL SECTION Centres and_Retail_Development

Objective 1 1 Shopping, a&i*istraUve, CtátUral cOmITliflity, entettainflient, eduCational. religiOuS and recreabormW Complies facilities located in integrated centres and med use zones.

Objective 2 2 Crtes that enswe rational, econon* and convenient pcovision of goods and services and pwvide: Corn plies

a bcus for conTnurity he

sale, penneate, pleesant and aces4e waftig and cydllng netxts.

P DC 1 1 Development slltwi ce*es shoild: Complies

riteate fac*ties widin the zone

allow for the miiipie use of facilities and the sha -ing of uhity spaces

(C) allow for the staging of development wøln the centre

(d) be integrated vAth pitlic and cotmuilty transport

PDC 2 2 Development wOm ce*es shoiád be cleelgned to be corrçatllAe vAM ac$oining arees This shoUld be promoted ttough landscaping, screen walls, centre oflerdation, location of access ways, bufr stnps

Corn nlies

and transitonal use areas

GENERAL SECTION Interface between Land Uses

0= Objective

PDC = Principle of Development Control

Objective DevieiMrnent located and desigried to prevert acaverse irnpact aincl caiict bdween land i Complies

PDC 1 Development should not detnmentalPy alTect the wnenity of the iocityorcause xweasone Complies interference ttwough any of the foMowing:

the ermssion Of efluent, odour, smole, times, ctist or other borne polutw*s

noise

(C) vtration

electrical i'derference

spill

glue

hours of Operabon

frafficNTacts.

PDC 2 2 Development should be sited and designed to minirrise negative ;nact on existing and potential future Complies anc uses desired ri the iocait

GENERAL SECTION Landscaping, Fences and Walls

Objective 1 T •Sifl it- €-rJ : - 0, tr Complies using locally indigenous plant species where possible

Objective 2 2 Functions fences and wells that er*iance the t Corn plies

0= Objective

PDC = Principle of Development Control

PDC 1 1 Development shotid uwporste open space and IandscspUig m order to: Complies

conçtemerd but bm and reckce the vmM ied ci Iwger buidngs (eq taller and broader pgs agnst tailler and biUer buing compmen)

enhance the sppeaice of road fronges

(C) screen service yards, k,adiig areas and oioor storage areas

nniae niiknance and wstering reqtWnenb

enhance and dee oiddocr spaces, icbfrg car pailung areas

piovide shade and shelter

aseist in cina cortol w0w txidrngs

mairtain pavacy

mese stomster ree

(J) conlement edsthg ive vegetabcn

(k) cordnt,ute to the vist,àty of ecosystems and speOes

(11 vornote water and b4oversJty conservation

GENERAL SECTION Orderly and Sustainable Development Objective 1 Orderly and economical development that creates a safe, convenient and pleasant environment in See Report

which to live.

Objective 4 Development that does not prejudice the achievement of the provisions of the Development Plan. See Report GENERAL SECTION

Transportation and Access

0= Objective

PDC = Principle of Development Control

Objective 1 2 Development amt Complies

provides safe and effiaient moverrd for ail[ transport modes

enaires access for vehides including emergency services,, pubic infrnsbuctuta maintenance an corinsrcial VehLdes

(C) provides aif street :paddflg

is appropriatdy located so that it stçpofls and makes best use of existing transport facilties and

provides converient and We access to pubic transport stops.

PDC 23 23 Dedopnentshoid beprovidedrwithsafeand convenientaccesswhiah: Complies

aids unreasonsb4e interference with the lIce, of traffic on acoining roais

provides appropriate separation distances fiom existing ioads or level crossings

accofflhlodetes the tWe and vokxne offrafilc likely to be generaled by the development or land use and miniiises induced baltic throt4i over-provision

is sited and designed to miniirise any adverse imparts on U eoccs of and visitors to ne4touing propees

P DC 43 43 Ve*c1e parking areas should be sealed or paved in order to n*inise &at and mud nuisance. Complies

PDC 45 45 VelEle parking areas should be li-marked to deineate perking bays movement aisles and ätii Corn plies ottiatic flov.

0= Objective

PDC = Principle of Developrnent Control

City of Charles Sturt 22. DAP Report 15/07/15

ATTACHMENT B

[Attachment B consists of 13 pages]

COUNCIL: CITY OF CHARLES STURT

APPLICANT: One Care Medical Centre Pty Ltd

Postal Address: CIo I Addison Road

Pennington SA 5013

OWNER: P. H. Tran

Postal Address:

BUILDER: -

Postal Address:

Licence No: -

CONTACT PERSON FOR FURTHER INFORMATION

ADS Architects

93 Gilles Street, Adelaide SA 5000

Name: Nic Salvati

Telephone: 8223 2244

Fax: 8223 2260

rVK uri-lut Ubt

Development No: .2. 2... ( 14 091 1 4 Previous Development No:

Assessment No: 1 S 2 5 7 0 Complying I Application forwarded to DA

o Non complying

o Notification Cat 2

0 Notification Cat 3

0 Referrals/Concurrences

0 DA Commission

Commission/Council on:

Decision:

Type:

Date:

Decision Fees Receipt No

required

Planning:

Building:

Land Division:

Additional:

Development Approval:

DESCRIPTION OF PROPOSED DEVELOPMENT:

DemolitIon of existing building change of use to car parking & fencing

LOCATION OF PROPOSED DEVELOPMENT:

House No: 5 Lot No:

Street: ADDISONS ROAD Town/Suburb: PENNINGTON

Section No (full/part): Hundred: Volume: 5940 Folio: 815

Section No (full/part): Hundred: Volume:. Folio:

LAND DIVISION

Site Area (m 2) Reserve Area (m 2) No of existing allotments:

Number of additional allotments (excluding road and reserve: Lease YESO NOD

BUILDING RULES CLASSIFICATION SOUGHT: Presentation classification:

If Class 5, 6, 7, 8 or9 classification is sought, state the proposed number of employees: Male: Female:

If Class 9a classification is sought, state the number of persons for whom accommodation is provided:

If Class 9b classification is sought, state the proposed number of occupants of the various spaces at the

premises:

DOES EITHER SCHEDULE 21 OR 22 OF THE DEVELOPMENT REGULATIONS 1993 APPLY? YESO NOD

HAS THE CONSTRUCTION INDUSTRY TRAINING FUND ACT 1993 LEVY BEEN PAID: YESD NOD

DEVELOPMENT COST (do not include any fit - out costs): $25,000.00

I acknowledge that copies of this application and supporting documentation may be provided to interested persons in accordance with the Development

Regulations 1993

SIGNATURE:

Dated: 2_f / 63 /

11

ADS Architects

arch lecture interiors facility plan fling

21 March 2014

2014 Ref: 11/JN1033/Co.CA

BY:'i.,

Ms. S. Hemingway Development Officer - Planning City of Charles Sturt P0 Box I Woodville SA 5015

Dear Sue

CHANGE OF USE ADDISON ROAD PENNINGTON - PLANNING APPLICATION

On behalf of the applicant, One Care Medical Centre Pty Ltd, ADS Architects forward sketch numbered

SK20 Illustrating the proposed car parking layout for a change of use application.

The proposal is to demolish the existing buildings and change the use to car parking as illustrated

together with new fencing and modification o the existing crossover.

Enclosed is a completed application form, Electricity declaration form and title together with a $122.00

check payable for the lodgement fee. It would be appreciated if a tax invoice for any additional application

fees can be emailed to ADS Architects (refer footer for address).

Should you require additional information or wish to discuss the proposal contact the undersigned.

Regards

Nic Salvati

Principal Architect

93 Gilles Street Adelaide South Australia 5000 Telephone: 0882232244 Facsimile : 08 8223 2260 Email : nic © adsarchitects . c7 . au

CONVEYANCING

File ref: 6690

7/11/2014

One Care Medical Centre

I Addison Road

Pennington SA 5013

c .9169197M

c ghtooa\

'-.. Brighton SA 5048

Phone 8296 2032

Mobile 0419 858 461

Re: Purchase of Allot 1 Addison Road Pennington SA 5013

Dear Dr Check Ng,

Just a brief note to confirm in writing that transfer of the above property has taken place on 31 Oct 2014 and the Certificate of Title is being processed to record your names as registered proprietors.

I have notified the City of Charles Sturt and SA Water of the change of ownership that has taken place.

Please find enclosed a settlement statement for your records.

Thank you for letting me represent you in this transaction. If there are any questions or problems dealing with Real Estate that I may help you with, please feel free to contact me at the above number.

Yours faithfully,

Cor Vermey Registered Conveyancer

A AUSTRALIAN

INSTITUTE OF CO NV E YA N CE R S

SA DI ISION INC

PROPERTYass,st

PropertyAssist - Results

PropertyAssist has found the following information.

Document Information

Title Searched

Title CT 5940/615

Status Current

Search Date 7 NOVEMBER 2014

Search Time 4:24:43 PM

Edition Edition 6

Documents

Prefix Document No Status Completion Date

DM 12221909 UNREGISTERED Not available

T 12221910 UNREGISTERED Not available

Data Available - Documents completed since 09/08/2014 & unregistered documents.

Documents Lodged With Plan

Registrar-General's Notes

Date Of Entry

10 JANUARY 2008 TEXTUAL AMENDMENT VIDE DD 10875221

Search Date 04:24 PM, Fri 07th November, 2014

i)

PropertyAssist Disclaimer Privacy Statement Copyright Government of South Australia

04:24:44 PM - 7 Nov 2014

The PropertyAssist application is managed by the Land Services Group of the Department of Planning, Transport and Infrastructure.

r1 -J

Title Register Search LANDS TITLES OFFICE, ADELAIDE

For a Certificate of Title issued pursuant to the Real Property Act 1886

REGISTER SEARCH OF CERTIFICATE OF TITLE * VOLUME 5940 FOLIO 615 *

COST : $0.00 (GST exempt ) PARENT TITLE : CT 5092/318 & OTHERS REGION : PIRPROD AUTHORITY : TG 9834528 AGENT : ATZ1 BOX NO : 288 DATE OF ISSUE : 13/05/2005 SEARCHED ON : 27/10/2014 AT : 19:51:49 EDITION : 6

REGISTERED PROPRIETOR IN FEE SIMPLE

PHONG NGUYEN TRAN OF 52 HAWKERS ROAD MEDINDIE SA 5081

DESCRIPTION OF LAND

ALLOTMENT 1 DEPOSITED PLAN 3021 IN THE AREA NAMED PENNINGTON HUNDRED OF YATALA

EASEMENTS

SUBJECT TO A FREE AND UNRESTRICTED RIGHT OF WAY OVER THE LAND MARKED A

TOGETHER WITH A FREE AND UNRESTRICTED RIGHT OF WAY OVER THE LAND MARKED B

SCHEDULE OF ENDORSEMENTS

11080154 MORTGAGE TO WESTPAC BANKING CORPORATION

NOTATIONS

DOCUMENTS AFFECTING THIS TITLE

NIL

REGISTRAR-GENERAL S NOTES

TEXTUAL AMENDMENT VIDE DD 10875221

END OF TEXT.

Page lof2

The Registrar-General certifies that this Title Register Search displays the records maintained in the Register Book and other notations at the time of searching.

Re5strar.General o

5

FP 12

MURES 0 2 4 8 12 16 26

Page 2 of 2

bottenIv.on develbprnent & environment lawyers

Our ref: JRB/214289

19 December2014

Ms Samantha McKinlay City of Charles Sturt P0 Box I WOODVILLE SA 5011

By em all: smckinlay©charlessturt.sa.gov.au

Dear Samantha

Response to representation - DA 252/1408/14 - 3 Addison Road, Pennington

This firm acts for One Care Medical Centre Pty Ltd, the applicant in respect of the above development application at 3 Addison Road, Pennington ("the land").

My client has instructed me to respond on its behalf to a representation received by the Council following public notification.

The representation

Only one representation was received following public notification, namely from Fassina (Pennington) Pty Ltd, the owner and operator of a liquor store on the adjacent land at 5 Addison Road.

2. Amended plans

In response to the representor's concerns about obstruction of the right of way, my client has amended the site plan to remove the proposed landscaping from the area of the right of way.

Accordingly, please find enclosed an amended plan, being drawing SK20/C prepared by ADS Architects, dated 6 November 2014.

Please also find enclosed a current copy of the Certificate of Title to the land, confirming that my client (ie, the applicant) is the registered proprietor of the land.

140 south terrace jrb:p214289_005.doc adelaide cc 5000

pa box 6777 halifax Street sa 5000

0882129777 f 08822S090 e 4JU

w 'rw,

-2--

3. Characterisation of the proposed development

The representor has asserted that the proposed development is in the nature of a "public open lot' carpark" that is "unconnected with the use of any buildings on adjacent or nearby sites". This in fact is not the case. The car park is proposed to be used solely in association with the existing medical centre operated by my client, at 1 Addison Road and 672 Torrens Road ("the medical centre".

The medical centre was, following approval by the Council, constructed in 2013 and presently contains a number of consulting rooms and other related spaces. I am instructed that my client is contemptating increasing the number of consulting rooms at the medical centre to provide a broader range of medical services. This will, of course, be the subject of a separate development application in due course.

My client wishes to use the land to create additional car parking to accommodate the present and future parking requirements of the medical centre. The proposed car park will not be available for use by the general public. In particular it is envisaged that the proposed car park will be used principally by staff of the medical centre, ensuring that the most conveniently located parking spaces are available for patients. Other users will be patients of the medical centre. Suitable signage will be erected at the entry to the car park and within the medical centre advising of the availability of the car park for users of the medical centre.

As Council staff would be aware, it is not uncommon for car parking demand to be accommodated on separate or additional sites.

To be clear, the proposed additional car parking is intended to be implemented regardless of whether the additional consulting rooms are brought into operation.

In the circumstances, it is wrong to characterise the nature of the development as a stand alone "car park".

In my opinion the proposed car park is not a use in its own right but rather is incidental or ancillary to the medical centre use. Thus, the proposed car park takes on the character of the predominant use, and is not a use to be separately characterised in its own right 1 . As stated by the Full Court of the Supreme Court in Adelaide City Investments Pty Ltd v Adelaide City Council:

As I have said, the present case is one in which the purpose of the use is significant. A use of land ancillary to another (predominant) use of land is not regarded for planning purposes as a use in its own right: see Ronecast Caterers Pty Ltd v Davis (1981) 26 SASR 545 at 546 - 547 King Ci and at 548 - 549 Sangster J; Davenport v Waverley Municipal Council (1981) 46 LGRA 97 at 108-109 Cripps J; Minister of

1 Potter v City of Holdfast Bay F20051 SASC 354; Corporation of the City of West Torrens v McDonald's Properties (Austretla) Pty Ltd (1985) 38 SASR 467

jrb:p21 4289_005.docx

na

-3-

Environment and Planning v District Council of Stirling (1990) 53 SASR 505 at 5 12-513 Matheson J. Thus, schools, churches, residential flats and offices, for example, often have car parking spaces adjacent to them. The use of that land for car parking does not require separate planning approval if the purpose of the use of those spaces is in connection with and ancillary to the use of the relevant building. Such a use of car parking spaces is, for planning purposes, treated differently from a use of those same spaces for the parking of cars by the public for purposes unconnected with the use of the relevant building. 2

A similar factual situation was also considered by the Full Court of the Supreme Court in Potter v City of Holdfast Bay where Justice Besanko commented:

in my view, the decision in Papadopoulos is expressed in terms which are too absolute. While it was correct to characterise the development as a car park, it was, nevertheless, a car park for a shopping centre. Except in the case of a large multi-storey car park, a car park usually serves a particular land use. One is used to seeing a car park for a shopping centre, for a hotel, for a school, for an office or for other kinds of uses. The nature and extent of the use of a car park will vary according to the nature of the use it is intended to serve.

Expressed another way, there is no logical basis for considering whether to grant planning approval to the establishment of a new car park to serve an existing use of land differently from the manner in which car parking forming part of the initial proposal would be considered.3 (my emphasis)

Similar comments were made by the Chief Justice in the recent Full Court decision of Caltex Australia Petroleum Pty Ltd v City of Holdfast Bay

The fragmentation of developments into their individual components, divorced from any context, would deny Development Plans of much of their efficacy. For example, the "multi-purpose hail" proposed to be constructed by Mercedes College was, in its proper context, a school hail. If so described, even though the multi-purpose hail would be just one of many buildings which together comprised Mercedes College, it is difficult to see why its construction was not the development of a school. Difficult questions of fact and degree would arise if incremental developments were assessed in isolation. 4

In the present case, the car parking centre use that it takes on that "development" requiring approval.

is so closely identified with the medical character. It is nonetheless an act of

2 [2004] SASC 309 at [20] [20051 SASC 354 at [19]- [20] [2014] SASCFC 59 at L251

rb:p214289_005.dOCX

-4-

In my view, the nature of the development is best described as "car parking in association with the existing medical centre at I Addison Road and 672 Torreris

Road".

There is no reason why the development plan consent granted by the Council cannot be expressed and limited in this fashion. My client is, of course, willing to submit to a condition of consent to that effect.

4. The zone

The representor has asserted that the proposed development is an inappropriate form of development in the Local Centre Zone. That contention is in the large part predicated on its incorrect characterisation of the proposal as stand alone, public "open lot" car park.

Objective 1 for the Local Centre Zone seeks:

A centre accommodating small-scale convenience shopping, office, service, medical and community facilities to serve the day-to-day needs of the local community.

As a development ancillary to a medical centre serving the day-to-day needs of the local community the proposed development is consistent with the objectives of the zone. A medical centre, of course, is an envisaged land use in the Zone. The objectives of the zone are supported, not defeated by the proposed development.

It must be kept in mind that the mix of uses within any Local Centre Zone will be dynamic and change over time. The loss of one use and its replacement with another is to be expected.

S. The locality

The representation asserts that the proposed development will be contrary to the established and desired character of the locality. The representor has described the area as consisting of a small group of small-scale convenience or 'corner store' style shops and a small-scale medical practice/consulting room.

In so doing, the representor has entirely overlooked the existence of my client's medical centre, which of course is a significant element in the locality.

Further, it must be accepted that the existing building proposed to be demolished is underwhelming in terms of its visual appearance and outdated. It has no intrinsic value.

It must also be accepted that a good proportion of the subject (and is already comprised of car parking at street frontage.

The proposed development will be well landscaped and have an improved interface with the residential property which abuts the boundary of the land for a length of around 7 metres.

jrb:p21 4289_OO5.docx

10

-5-

In this regard it must also be noted that the Development Plan contains specific direction in respect of the Cheltenham Parade I Torrens Road Local Centre, commenting in the Desired Character statement that:

It will be necessary to upgrade the centre in terms of presentation and range of services and to rationalise and landscape its car parking areas.

In my submission the proposed development is generally consistent with the Desired Character for the area.

6. Hypothetical development?

The argument that the proposed development is hypothetical was misconceived in the first place but has been conclusively addressed by the amendment to the plan and proof of ownership. There is no question that, if approved, the proposed development can be implemented.

7 Operation and security

The proposed car parking area will be open during the usual hours of the medical centre, namely:

• Monday to Friday 8 am - 8 pm • Saturday and Sunday 8 am - 5 pm

Outside of those hours the gate will be kept closed.

Low level bollard lighting is proposed within the car park to provide safety to staff and patients.

8. Summary

The representor's concerns have been addressed by the amendments to the proposal and the information in this letter. The concerns are in the large part, misplaced.

The proposed development is consistent with the objectives of the Local Centre Zone and will not compromise the amenity, functionality or purpose of the Zone. It will support the operation of the existing Medical Centre.

In short, the proposal is a good one. It is ancillary to an envisaged use (viz, a medical centre). In the circumstances, the Council's Development Assessment Panel is therefore urged to grant development plan consent to it.

jrb:p2142B9_005dQcx

11

My client or its representative wishes to appear before the Panel to speak in support of the application. Accordingly, I would be grateful if you could advise me in due course as to the date and time of the relevant meeting.

Yours faithfully

~'_M 9qv- i2 Jamie Botten f'( BOTTEN LEVINSON

Mob: 0419 816 598 Email: jrbbIIawyers.com.au

Enc:

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CHANGE OF USE - CARPARKING 5 ADDISON ROAD PENNINGTON

22.01.15 PLANNING APPLICATION A D S Architects I 1/J NI 0331SK201C

93 Glues Street Adelaide 5000 T:82232244

/ 13

City of Charles Sturt 23. DAP Report 15/07/15

ATTACHMENT C

[Attachment C consists of 13 pages]

Expert, advice, human approach.

WALLMANS LAWYERS

Our Ref BDA:yxv142989

6 November 2014

Chief Executive Officer City of Charles Sturt P0, Box I WOOD VILLE SA 5011

AND BY FAX: 8408 1122

Your Ref. 25211408/14

15, 400 Ing William St Adelaide 545000

GPO Box 1018 Adelaide 545001

Tel (08) 8235 3000 Fax (08)82320926 -

general©waflmans.comau vw.wallmans.com.au

ABN 98802 494 422

AND BY EMAIL: counciltãcharIessturt.sa.uov.au

Dear Sir

ONE CARE MEDICAL CENTRE PTY LTD REPRESENTATION OF OBJECTION TO DEVELOPMENT APPLICATION FOR CHANGE IN USE FROM SHOP TO CARPARKING WITH ASSOCIATED LANDSCAPING AT 3 ADDISON ROAD PENNINGTON SA 5013 DA 252/1408114

We act for Fassina (Pennington) Pty Ltd (Fassina). Fassina owns and operates a liquor store at 5 Addison Road, Pennington, immediately adjacent to the subject site. We are instructed to make this representation of objection on behalf of Fassina in respect of the above application in accordance with Section 38(7) of the Development Act 1993 and Regulation 35 of the Development Regulations 2008.

We have inspected the proposed development site, we have examined the documentation lodged with City of Charles Sturt (Council) in support of the application and we have considered the relevant provisions of the Development Plan.

INTRODUCTION

Fassina received written notice from Council of a development application for a category 2 development at 3 Addison Road, Pennington (Subject Land). The proposed development has been described by the Council as "change in use from shop to carparking with associated landscaping".

Fassina owns the land at 5 Addison Road, Pennington (Fassina Land). The Subject Land is immediately adjacent to the South of the Fassina Land.

The Subject Land is located in the Local Centre Zone of the Council's Development Plan (Consolidated —25 September 2014).

SUBJECT LAND AND LOCALITY

There are 2 small shops currently located on the Subject Land - a chemist and a Vietnamese food takeaway shop, veiy much in the nature of traditional 'corner shops' serving the local community.

1152065_I ::142989;:BDA::SAK

I

The Chief Executive Officer City of Charles Sturt -2 - 6 November 2014

There is a small medical practicelconsuiting rooms operating out of what appears to be a former dwelling currently located on the land immediately to the North of the Fassina Land.

The land to the South of the Subject Land is currently vacant.

The area, therefore, consists of a small group of small-scale convenience or 'corner store' style shops (a chemist, a Vietnamese food takeaway shop and our client's liquor store) and a small-scalemedical practice/consulting room.

EXISTING USE

The Subject Site is currently being used for the sale by retail of goods, foodstuffs, merchandise or materials and/or a restaurant The shops operating from the Subject Site are small in scale and consist of a chemist and a Vietnamese food takeaway shop.

The use of the Subject Site is very much in keeping with the objectives of the Local Centre Zone. The Local Centre Zone should be a centre accommodating small-scale shops (amongst other things) serving the day-to-day needs of the local community.

THE PROPOSED USE

The proposed development is described by the Council as "change in use from shop to carparking with associated landscaping". On the information made available to our client, the proposed development appears to be a public 'open lot' carpark unconnected with the use of any buildings on site (the existing buildings are proposed to be demolished) and unconnected with the use of any buildings on adjacent or nearby sites. On the face of the application documents made available to our client, the proposed use appears to be a carpark In its own right

No information has been made available about the operation of the carpark (hours of operation, security, method of payment etc).

Fassina objects to the proposed change in use of the Subject Land from shop as a carpark because it offends the objectives, desired character and principles of development control of the Local Centre Zone.

RELEVANT DEVELOPMENT PLAN CONSIDERATIONS

The Subject Land is located in the Local Centre Zone of the Council's Development Plan (Consolidated —25 September 2014)

The relevant provisions of the Local Centre Zone are set out as follows.

Objective I - "A centre accommodating small-scale convenience shopping, office, service, medical and community facilities to serve the day-to-day needs of the local community."

Objective 2 - "A centre characterised by traditional corner stores or small groups of shops located within easy walking distance of the population they serve."

Desired Character - "All centres in this zone will continue to provide a local centre function provided the gross leasable floor area or a shop or group of shops does not exceed 450 square metres."

1 152085_i ::142989::BDA:SAJ(

PAI

The Chief Executive Officer City of Charles Sturt -3- 6 November 2014

The Development Plan clearly encourages the continued use of land in the zone for local centre purposes - small scale shops, offices, service facilities, medical facilities and community facilities. Changing the use of land in the Local Centre Zone from an existing shop (i.e. discontinuing a shop use) is not supported by the Local Centre Zone objectives and desired character provisions (unless the proposed 'replacement' use of the land was a small scale office, service facilities, medical facilities or community facilities). The demolition of the small scale, traditional 'corner shop' style shops currently on the Subject Land defeats the objectives and desired character of the Local Centre Zone, which seek to support the continued use of land in the Local Centre Zone for these purposes.

A public 'open lot' carpark is not envisaged in the Council's Local Centre Zone. The development proposal does not maintain the local centre function as is desired by the Zone.

The proposal is also inconsistent with the Council Wide Objectives and Principles of Development Control - Centres and Retail Development - see Objectives 1, 2, 5 and Principle 1, and Orderly and Sustainable Development - see Objectives 1, 2, 4 and Principles 1, 5 and 8.

HYPOTHETICAL DEVELOPMENT

The Development Application form made available to us does not list the owner of the property. The property search made available to us lists a Phong Nguyen Tran as the Registered Proprietor. On the material provided to us, there is no apparent link between the applicant and the property.

Further, the property search notes that the subject site is "Subject to a free and unrestricted right of way over the land marked A. That right of way is in favour of Fassina - see attached property search for CT 59401616.

The plans of the development provided to us appear to restrict the right of way.

For the above reasons, it is apparent that the application is hypothetical and should not proceed any further.

CONCLUSION

For the reasons set out above our client maintains that the proposed development is seriously at variance with the Development Plan. The proposed public 'open lot' carpark is not in keeping with the locality, which currently functions as a local centre where small scale traditional corner shops and small Scale offices, service facilities, medical facilities and community facilities are envisaged and encouraged.

The proposed development is inconsistent with and in conflict with the Development Plan in particular Objectives I and 2 and the Desired Character of the Council's Local Centre Zone.

The applicant has no apparent link with the subject site, and the development proposal appears to restrict an existing right of way in favour of our client.

For all of the above reasons our client asks that Council refuse consent for this application.

In accordance with Section 38(10) and Regulations 35 and 37 would you be kind enough to advise of the time, date and place of any meeting of Council, its committees or delegated

1 152O65_1::142989::BDASAJ(

3

The Chief Executive Officer City of Charles Sturt -4 - 6 November 2014

officers who might consider this application so that we might appear with and on behalf of our client and be heard in support of this representation of objection.

Yours faithfully WWMANSLWYERS

BEN ALLEN Partner Direct Line: 08 8235 3018 Email: ben.ailen@wallmans.com.au

Enc CT 5940/616 Council Representation Form

1 152065_I ::142989::BDA;SAK

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Title Register Search A. LANDS TITLES OFFICE, ADELAIDE For a Certificate of litte issued pu'suentto the Real Property Act 1886

REGISTER SEARCH OF CERTIFICATE OF TITLE * VOLUME 5940 FOLIO 616 *

COST : $26.50 (GST exempt ) PARENT TITLE : CT 5092/318 6 OTHERS REGION : E!L AUTHORITY : TO 9834528 AGENT WALL BOX NO : 571 DATE OF ISSUE : 13/05/2005 SEARCHED ON : 30/10/2014 AT : 17:01:12 EDITION : 5 CLIENT REF BDA:142989

REGISTERED PROPRIETOR IN FEE SIMPLE -

FRSSINA (PENNINOTON) PTT. LTD. OF 35-39 OAKLANDS ROAD SONERTON PARK 8k 5044

DESCRIPTION OF LAND

ALLOTMENT 2 DEPOSITED PLAN 3021 IN THE AREA NAMED PENNINGTON HUNDRED OF TATALA

EASEMENT S

SUB33CT TO A FREE AND UNRESTRICTED RIGHT OF WAY OVER THE LAND )BKED B

TOGETHER WITH A FREE AND UNRESTRICTED RIGHT OF WAY OVER THE LAND MBKED A

SCHEDULE OF ENDORSEMENTS

NIL

NOTATIONS

DOCUMENTS AFFECTING THIS TITLE

NIL

REGISTRAR—GENERAL' S NQTES

TEXTUAL AMENDMENT VIDE DD 10875215 TEXTUAL AMENDMENT VIDE DD 10875879 TEXTUAL AMENDMENT VIDE DD 11368843

END OF TEXT.

Page 1 of 2

maintained in the Register Book and other notations at the time of searching. The Registrar-General certifies that this Title Register Search displays the records

)

FP 12

LANDS TITLES OFFICE ADELAIDE SOUTH AUSTRALIA

DIAGRAM FOR CERTIFICATE OF TITLE VOLUME 5940 FOLIO 616

SEARCH DATE: 30/10/2014 TIME: 17:01:12

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FKI Statement of Representation Pursuant to Section 38 of the Development Act 1993 Under the Development Act 1993, any person may, in acxordance with the regulations, make a representation In writing to the relevant authority in relation to the granting or refusal of consent for a Category 2 or Category 3 development apphcation. To submit a statement of representation please complete ALL P. sections of this form and send to council.

Please note that pursuant to section 38(17) of the Development Act 1993, if the application involves a Category 2 notification and you were not entitled to receive notice of the application in accordance with the Development Act 1993 and Development Regulations 2008 you cannot make a representation in relation to the application.

1. Development Number 252

House No:. Street: AvA Suburb: V41 I,, f

*2. Person(s) making representation:

Name: (Mr/Ms/Ms) vtflf

Street Address:

Postal Address if different to above)(.( _ I.kr/sa_q,,r_ [.0IcoA_/C1_K Email: bei /fei '!/,a; (oi 'qu 500 /

Phone: S 23 S__Mobile: Fax:

*3 Please Indicate whether you wish to personally present your statement to the Development Assessment Panel. Your written statement will be provided to the Development Assessment Panel and to the appJicarit, and will be considered in making on approval decisIon. You may choose to present your statement verbally.

O Please tick one of the boxes below

O I do not wish to make a verbal presentation.

will appear personally to make a verbal presentation.

j4thorise e4' Jj/e 1 to make the verbal representation on my behalf

*4• Nature of interest in development (eg adjoining resident, owner of land In vicinity or on behalf of organisation or company):

OtA&ii,, e,c- fa.v.,k kj/'icij

•5 Issues that I/we would like to raise:

Se. letky-

h

botten V fl2fl - development & enviont Iawyer

Our ref: JRB/2 14289

19 December2014

Ms Samantha McKinlay City of Charles Sturt P0 Box I WOODVILLE SA 5011

By email: smckinlay@charlessturt.sa.gov.au

Dear Samantha

Response to representation - DA 252/1408/14 - 3 Addison Road, Pennington

This firm acts for One Care Medical Centre Pty Ltd, the applicant in respect of the above development application at 3 Addison Road, Pennington ("the land").

My client has instructed me to respond on its behalf to a representation received by the Council following public notification.

The representation

Only one representation was received following public notification, namely from Fassina (Pennington) Pty Ltd, the owner and operator of a liquor store on the adjacent land at 5 Addison Road.

Amended plans

In response to the representor's concerns about obstruction of the right of way, my client has amended the site plan to remove the proposed landscaping from the area of the right of way.

Accordingly, please find enclosed an amended plan, being drawing SK20/C prepared by ADS Architects, dated 6 November 2014.

Please also find enclosed a current copy of the Certificate of Title to the land, confirming that my client (ie, the applicant) is the registered proprietor of the land.

40 south terrace )rb:p214289_005.docc adelaide sa 5000

po box 6777 halifax street sa 5000

08 8212 9777 f 6212 e r 0wyor5cQJ 1

w VAAW

-2--

3. Characterisation of the proposed development

The representor has asserted that the proposed development is in the nature of a "public 'open lot' carpark" that is "unconnected with the use of any buildings on adjacent or nearby sites". This in fact is not the case. The car park is proposed to be used solely in association with the existing medical centre operated by my client, at 1 Addison Road and 672 Torrens Road ("the medical centre".

The medical centre was, following approval by the Council, constructed in 2013 and presently contains a number of consulting rooms and other related spaces. I am instructed that my client is contemplating increasing the number of consulting rooms at the medical centre to provide a broader range of medical services. This will, of course, be the subject of a separate development application in due course.

My client wishes to use the land to create additional car parking to accommodate the present and future parking requirements of the medical centre. The proposed car park will not be available for use by the general public. In particular it is envisaged that the proposed car park will be used principally by staff of the medical centre, ensuring that the most conveniently located parking spaces are available for patients. Other users will be patients of the medical centre. Suitable signage will be erected at the entry to the car park and within the medical centre advising of the availability of the car park for users of the medical centre.

As Council staff would be aware, it is not uncommon for car parking demand to be accommodated on separate or additional sites.

To be clear, the proposed additional car parking is intended to be implemented regardless of whether the additional consulting rooms are brought into operation.

In the circumstances, it is wrong to characterise the nature of the development as a stand alone 'car park".

In my opinion the proposed car park is not a use in its own right but rather is incidental or ancillary to the medical centre use. Thus, the proposed car park takes on the character of the predominant use, and is not a use to be separately characterised in its own right 1 . As stated by the Full Court of the Supreme Court in Adelaide City Investments Pty Ltd vAdelaide City Council:

As / have said, the present case is one in which the purpose of the use is significant. A use of land ancillary to another (predominant) use of land is not regarded for planning purposes as a use in its own right: see Ronecast Caterers Pty Ltd v Davis (1981) 26 SASR 545 at 546 - 547 King CJ and at 548 - 549 Sangster J; Davenport v Waverley Municipal Council (1981) 46 LGRA 97 at 108-109 Cr!pps J; Minister of

Potter v City of Holdfasf Bay [20051 SASC 354; Corporation of the City of West Torrens v McDonald's Properties (Australia) Pty Ltd (1985) 38 SASR 467'

jrb:p21 4289_005.dOCx

-3-

Environment and Planning v District Council of Stirling (1990) 53 SASR 505 at 512-513 Matheson J. Thus, schools, churches, residential flats and offices, for example, often have car parking spaces adjacent to them. The use of that land for car parking does not require separate planning approval if the purpose of the use of those spaces is in connection with and ancillary to the use of the relevant building. Such a use of car parking spaces is, for planning purposes, treated differently from a use of those same spaces for the parking of cars by the public for purposes unconnected with the use of the relevant building. 2

A similar factual situation was also considered by the Full Court of the Supreme Court in Potter v City of Holdfast Bay where Justice Besanko commented:

In my view, the decision in Papadopoulos is expressed in terms which are too absolute. While it was correct to characterise the development as a car park, it was, nevertheless, a car park for a shopping centre. Except in the case of a large mulfi-storey car park, a car park usually serves a particular land use. One is used to seeing a car park for a shopping centre, for a hotel, for a school, for an office or for other kinds of uses. The nature and extent of the use of a car park will vary according to the nature of the use it is intended to serve.

Expressed another way, there is no logical basis for considering whether to grant planning approval to the establishment of a new car park to serve an existing use of land differently from the manner in which car parking forming part of the initial proposal would be considered. 3 (my emphasis)

Similar comments were made by the Chief Justice in the recent Full Court decision of Caltex Australia Petroleum Pty Ltd v City of Holdfast Bay

The fragmentation of developments into their individual components, divorced from any context, would deny Development Plans of much of their efficacy. For example, the multi-purpose hail" proposed to be constructed by Mercedes College was, in its proper context, a school hail. If so described, even though the multi-purpose hail would be just one of many buildings which together comprised Mercedes College, it is difficult to see why its construction was not the development of a school. Difficult questions of fact and degree would arise if incremental developments were assessed in isolation. 4

In the present case, the car parking is so closely identified with the medical centre use that it takes on that character. It is nonetheless an act of "development" requinng approval.

2 [2004] SASC 309 at [20] 120051 SASC 354 at [19]- (20] [2014] SASCFC 59 at [25]

rb:p214289_005.d0CX

10

-4-

In my view, the nature of the development is best described as "car parking in association with the existing medical centre at I Addison Road and 672 Torrehs

Road'.

There is no reason why the development plan consent granted by the Council cannot be expressed and limited in this fashion. My client is, of course, willing to submit to a condition of consent to that effect.

The zone

The representor has asserted that the proposed development is an inappropriate form of development in the Local Centre Zone. That contention is in the large part predicated on its incorrect characterisation of the proposal as stand alone, public "open lot" car park.

Objective 1 for the Local Centre Zone seeks:

A centre accommodating small-scale convenience shopping, office, service, medical and community facilities to serve the day-to-day needs of the local community.

As a development ancillary to a medical centre serving the day-to-day needs of the local community the proposed development is consistent with the objectives of the zone. A medical centre, of course, is an envisaged land use in the Zone. The objectives of the zone are supported, not defeated by the proposed development.

It must be kept in mind that the mix of uses within any Local Centre Zone will be dynamic and change over time. The loss of one use and its replacement with another is to be expected.

The locality

The representation asserts that the proposed development will be contrary to the established and desired character of the locality. The representor has described the area as consisting of a small group of small-scale convenience or 'corner store' style shops and a small-scale medical practice/consulting room.

In so doing, the representor has entirely overlooked the existence of my client's medical centre, which of course is a significant element in the locality.

Further, it must be accepted that the existing building proposed to be demolished is underwhelming in terms of its visual appearance and outdated. It

has no intrinsic value.

It must also be accepted that a good proportion of the subject land is already comprised of car parking at street frontage.

The proposed development will be well landscaped and have an improved interface with the residential property which abuts the boundary of the land for a length of around 7 metres.

jrt,:p21 4289005.docx

11

-5-

In this regard it must also be noted that the Development Plan contains specific direction in respect of the Cheltenham Parade / Torrens Road Local Centre, commenting in the Desired Character statement that: -

It will be necessary to upgrade the centre in terms of presentation and range of services and to rational/se and landscape its car parking areas.

In my submission the proposed development is generally consistent with the Desired Character for the area.

6. HypothetIcal development?

The argument that the proposed development is hypothetical was misconceived in the first place but has been conclusively addressed by the amendment to the plan and proof of ownership. There is no question that, if approved, the proposed development can be implemented.

7.. Operation and security

The proposed car parking area will be open during the usual hours of the medical centre, namely:

• Monday to Friday 8 am - 8 pm

• Saturday and Sunday 8 am - 5 pm

Outside of those hours the gate will be kept closed.

Low level bollard lighting is proposed within the car park to provide safety to staff and patients.

S. Summary

The representor's concerns have been addressed by the amendments to the proposal and the information in this letter. The concerns are in the large part, misplaced.

The proposed development is consistent with the objectives of the Local Centre Zone and will not compromise the amenity, functionality or purpose of the Zone. It will support the operation of the existing Medical Centre.

In short, the proposal is a good one. It is ancillary to an envisaged use (viz, a medical centre). In the circumstances, the Council's Development Assessment Panel is therefore urged to grant development plan consent to it.

Irb:0214289_005.docx

12

S

My client or its representative wishes to appear before the Panel to speak in support of the application. Accordingly, I would be grateful if you could advise me in due course as to the date and time of the relevant meeting.

Yours faithfully

JM A tZ, JamleBotten Y1 BOTTEN LEVINSON

Mob: 0419 816 598 Email: jrbbllawyers.com.au

Enc:

J,t:p214289_005.docx

13

City of Charles Sturt 24. DAP Report 15/07/15

ATTACHMENT D

[Attachment D consists of 3 pages]

In reply please quote 2014/01881/01, Process ID: 304171 1'.0 Enquiries to Paul Silvestri Telephone (08) 8343 2744 Facsimile (08) 8343 2725 E-mail dpti.lucsa.gov.au

29/10/2014

Ms Samantha McKinlay City of Charles Sturt P0 Box 1 WOODVILLE SA 5011

Government of South Australia

Department of Planning, Transport and Infrastructure

SAFETY AND SERVICE DIVISION

77 GrenfelI Street Adelaide SA 5001

GPO Box 1533 Adelaide SA 5001

Telephone: 61 8 8343 2222 Facsimile: 61 8 8343 2585

Dear Ms Mckinlay,

SCHEDULE 8- REFERRAL RESPONSE

Development No. 252/1408/14 Applicant One Care Medical Centre Location Lot 1 in DP 3021, 3-5 Addison Road, Pennington Proposal Change use from shop to car parking.

I refer to the above development application forwarded to the Safety and Service Division of the Department of Planning, Transport and Infrastructure (DPTI) in accordance with Section 37 of the Development Act 1993. The proposed development involves development adjacent a main road as described above.

The following response is provided in accordance with Section 37(4)(b) of the Development Act 1993 and Schedule 8 of the Development Regulations 2008.

THE PROPOSAL

The application proposes to demolish an existing shop and change the use of the land to car parking for the nearby medical centre. DPTI received amended plans on 2 October 2014 in response to DPTI letter dated 4 August 2014.

CONSIDERATION

Access

It is DPTI policy to minimise the number of access points on the arterial road network in the interests of road safety, therefore the rationalisation of access to a single access point to serve the site is supported. It is noted that the single access provides a width of 6.0 metres at the property boundary to facilitate simultaneous two-way vehicle movements.

Furthermore, it is noted that two of the four car parks located within the 6.0 metre by 6.0 metre access clear area have been removed. Whilst it remains DPTI's preference that the 2 car parks adjacent the northern side of the access are removed and replaced with landscaping, the proposed arrangement is tolerable should these car parks be designated as staff car parking. This will reduce the vehicle turnover of these spaces, thereby reducing the number of vehicles required to manoeuvre within the clear area and potentially into the path of vehicles entering/exiting the site. KNet 8964959

1

2

It appears that the gate has been located at a distance inbound into the property that will allow a vehicle to store off-street while the gate is being opened/closed. The gate should remain open during medical centre opening hours.

All redundant crossovers should be deleted and reinstated with kerb and gutter at the applicant's cost. Council should ensure that the crossover at the northern boundary is altered to provide sufficient flaring to ensure convenient ingress/egress movements can be maintained, particularly for delivery/refuse vehicles, to/from Lot 2 (DP3021).

With regard to car parking and manoeuvring, it appears that sufficient space is available for a B85 vehicle to enter and exit the site in a forward direction.

Metropolitan Adelaide Road Widening Plan

The Metropolitan Adelaide Road Widening Plan shows a possible requirement for a strip of land up to 4.5 metres in width from the Addison Road frontage of this site for future upgrading of the Addison Road / Torrens Road / Cheltenham Parade / Burleigh Avenue intersection. Although it is considered unlikely that any land would be required from this property, the consent of the Commissioner of Highways under the Metropolitan Adelaide Road Widening Plan Act is required to all building works on or within 6.0 metres of the possible requirement.

CONCLUSION

In light of the above, DPTI does not object in-principle to the development in its current form, subject to the two car parks located within the access clear area being designated as staff car parking to reduce the number of vehicles required to manoeuvre within the clear area and potentially into the path of vehicles entering/exiting the site.

ADVICE

The planning authority is advised to attach the following conditions to any approval:

Access shall be provided in accordance with the plan designated as Change of Use: Car parking - 11/JN1033/SK20/A, dated 3/9/14.

All vehicles shall enter and exit the site in a forward direction.

The existing redundant crossovers shall be closed and reinstated to Council satisfaction at the applicant's cost.

Stormwater run-off shall be collected on-site and discharged without jeopardising the integrity and safety of the arterial road. Any alterations to the road drainage infrastructure required to facilitate this shall be at the applicant's cost.

The following note provides important information for the benefit of the applicant and is required to be included in any approval:

• The Metropolitan Adelaide Road Widening Plan shows a possible requirement for a strip of land up to 4.5 metres in width from the Addison Road frontage of this site for future upgrading of the Addison Road I Torrens Road I Cheltenham Parade / Burleigh Avenue intersection. Although it is considered unlikely that any land would be required from this property, the consent of the Commissioner of Highways under the Metropolitan Adelaide Road Widening Plan Act is required to all building works on or within 6.0 metres of the possible requirement.

KNet 8964959

PIA

3

Yours sincerely,

a---- - MANAGER, TRAFFIC AND ACCESS STANDARDS

for COMMISSIONER OF HIGHWAYS

A copy of the decision notification form should be forwarded to: Land Use Co-Ordination Unit Traffic and Access Standards Section Department of Planning, Transport and Infrastructure GPO Box 1533 ADELAIDE SA 5001

KNet 8964959

3

City of Charles Sturt 25. DAP Report 15/07/15

ATTACHMENT E

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DEVELOPMENT ACT 1993

Section 38 (Category 2)

Public Notice and Consultation Authorisation

Pursuantto Section 38(4) of the Act to give notice of a

proposalfor a Category 2 development.

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show the occupiers and recorded owners of all properties

which have been notified pursuantto Section 38(4) of the

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Authorityto form such opinion and to give notice is

delegated tothe Team Leader Major PlanningAssessment.

Development Application No. 2521 1408 / 14

Signed Zoe Garnaut

(Team LeaderMajor Planning Assessment)

Date 28/05/2015

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