Grange Planning Brain

title: Commercial Land and Activity Centre Strategy (CLACS) 2015 council: greater-bendigo state: vic category: strategy classification: MAJOR status: unknown last_compiled: 2026-05-31 source_docs:

  • agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf

Commercial Land and Activity Centre Strategy (CLACS) 2015

The available corpus does not contain the Commercial Land and Activity Centre Strategy itself, so this page analyses CLACS through its later use in a 2026 statutory planning report for a restricted-retail proposal at 145-157 and 159-165 Midland Highway, Epsom. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.59) The available evidence shows CLACS functioning as an activity-centre hierarchy and commercial floorspace demand reference, rather than as a detailed precinct design or infrastructure-staging document. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71)

Background

CLACS is cited in the 2026 agenda as the Commercial Land and Activity Centre Strategy 2015, and it is used alongside Clause 11.03-1L of the Greater Bendigo Planning Scheme to identify Epsom as a large activity centre. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The same report states that CLACS sets floorspace forecasts for the Epsom activity centre to 2031 and identifies a need for additional commercial floorspace in line with population growth in Epsom. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

The available source places CLACS within a broader planning context in which Bendigo is described as Victoria’s third-largest urban centre outside metropolitan Melbourne, the major centre for north-central Victoria, and the key regional city and economic growth hub for the Loddon Mallee South Region. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.88-91) The planning scheme context also records a projected Greater Bendigo population of 150,000 people by 2036 and a population target of 200,000 by 2051. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.88)

Analysis

Strategic Function: Demand Forecasting Without Precinct Resolution

CLACS appears to perform a demand-allocation role by identifying activity centres and forecasting commercial floorspace need, with Epsom specifically forecast to 2031. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The practical effect is that CLACS can support additional commercial floorspace in identified centres, but the available source does not show CLACS resolving detailed centre boundaries, built-form expectations, access arrangements, or staging responsibilities. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76)

This matters because the Epsom assessment states that no structure plan exists for Epsom and that the activity-centre boundaries are not completely defined. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) In the absence of a structure plan, officers treated the core activity-centre boundary as broadly corresponding to Commercial 1 zoned land north-east of Howard Street, while also supporting a Commercial 2 zoned restricted-retail site on the Midland Highway near Epsom Village Shopping Centre. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.71, 74-75)

The mechanism is therefore loose rather than prescriptive: CLACS supplies strategic demand justification, while the zoning, overlays, referral responses, and permit conditions do the detailed regulatory work at application stage. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-83) That creates flexibility for commercial land take-up, but it also leaves important urban-structure questions to be negotiated case by case through individual permit assessments. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-83)

Epsom as the Available Test Case

The Epsom permit report is the only available source document that applies CLACS directly. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The proposal concerned a 1.79 hectare Commercial 2 Zone site at 145-157 and 159-165 Midland Highway, Epsom, with four restricted-retail buildings and associated works. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.59-64) The proposed tenancy floorspace was 2,612 square metres for Tenancy A, 3,427 square metres for Tenancy B, 2,017 square metres for Tenancy C, and 1,012 square metres for Tenancy D, giving a total leasable floorspace of 9,078 square metres. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.63, 79)

The available source indicates that CLACS was used to support the proposition that Epsom needs additional commercial floorspace as population grows. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) The report records forecast population growth for Epsom-Ascot from 7,375 people in 2021 to 9,830 people in 2046, an increase of close to 2,500 residents. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) That growth figure is the clearest quantified demand signal available in the corpus, although it extends beyond the 2031 CLACS forecast horizon. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

The planning consequence is that Epsom is being treated as both a suburban catchment centre and a wider northern-corridor service location. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The report states that Epsom is likely to remain a shopping destination in the short to medium term for residents from Huntly and further north, but that this may change as the commercial centre in Huntly grows. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

Activity-Centre Boundary Ambiguity

The most important analytical issue is the gap between CLACS-level centre identification and local precinct definition. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76) The report expressly states that Epsom has no structure plan and that this is subject to future work. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.70) It also states that activity-centre boundaries are not completely defined in Epsom. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

This produces a clear cause-and-effect chain. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76) CLACS identifies demand and centre role, but because there is no Epsom structure plan or adopted urban design framework referenced in the planning scheme, the responsible authority assessed setbacks, frontage activation, car parking layout, and landscaping through general policy and permit conditions rather than through a precinct-specific built-form control. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76)

The report shows this limitation directly in the built-form assessment. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.76) The City Urban Designer recommended locating buildings close to the front boundary, improving pedestrian links, separating service access from pedestrian links, using full-height glazed shopfronts, adding landscape detail, and providing tree canopy cover through the car park. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) However, the report notes that there is no adopted urban design framework for the locality referenced in the planning scheme and no Design and Development Overlay setting preferred building setbacks. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.76)

The practical result is that a 37.67 metre front setback for Tenancy B was accepted because the proposal was considered similar to other large-scale commercial development on the highway. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.76) This illustrates that CLACS can justify commercial floorspace distribution but does not, on the available evidence, resolve the public-realm form of highway-based commercial development. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76)

Transport and Access as the Binding Implementation Mechanism

The Epsom case shows that commercial floorspace supported by CLACS still depends on arterial-road access resolution. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.68-79) The site fronts Midland Highway, which is a Transport Zone 2 road managed by the Department of Transport and Planning. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.61, 69)

The Department of Transport and Planning did not object, subject to conditions requiring a functional layout plan, traffic signals at the Midland Highway, Maynard Drive, and site-access intersection, two channelised right-turn treatments on Midland Highway, an auxiliary left-turn treatment on the western side of Midland Highway, a pedestrian crossing across Midland Highway, a right-turn treatment at the Bendigo Pottery access road, bicycle lanes on the northern and southern approaches, line marking and signage, a road safety audit, a traffic signal plan, and an updated traffic impact assessment. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.69-70)

This is a strong implementation signal: CLACS may support additional floorspace, but the physical permission pathway is controlled by arterial-road design, safety, and state transport consent. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.69-79) The report states that the access design was amended from multiple access points, including Tierney Lane, to a single signalised Midland Highway access aligned with Maynard Drive. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.78-84) The amended access arrangement also included a right-turn lane treatment into Bendigo Pottery and removed vehicle access via Tierney Lane. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.78-79)

The arterial-road dependency also shows how unresolved centre planning can transfer integration issues into individual applications. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.72-79) Objectors raised concerns about Midland Highway and Howard Street congestion, pedestrian and cycling safety near Epsom Primary School and the Bendigo Creek trail, access to Bendigo Pottery, use of Tierney Lane, and potential Midland Highway land acquisition for widening or future upgrades. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.72-73) These issues are precinct-structure matters as much as site-permit matters, but the available evidence shows them being resolved at permit stage through amended plans and referral conditions. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.78-79)

Parking, Mode Share, and Large-Format Retail Form

The Epsom case also shows the tension between CLACS-supported commercial floorspace and car-oriented large-format retail design. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.79-80) The planning scheme generated a car-parking requirement of 272 spaces for 9,078 square metres of restricted-retail floorspace, based on 3 spaces per 100 square metres of leasable floor area. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.79) The proposal provided 151 spaces, creating a 121-space shortfall and requiring a parking reduction. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.79)

The parking reduction was supported because a parking assessment of 28 comparable Victorian sites found average peak parking demand of 1.14 spaces per 100 square metres on weekdays and 1.41 spaces per 100 square metres on Saturdays, which translated to anticipated peak demand of 98 spaces on weekdays and 122 spaces on weekends. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.79) The source records that the proposed 151 spaces would exceed the assessed likely demand. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.79)

The bicycle-facility assessment reveals a similar implementation tension. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.79-80) The planning scheme generated a requirement for 33 bicycle spaces, made up of 15 employee spaces and 18 shopper spaces. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.80) The proposal initially provided 9 employee spaces and 9 shopper spaces, but officers considered that at least 14 employee spaces and 14 visitor spaces should be provided. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.80)

The planning implication is not simply that parking was reduced. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.79-80) It is that CLACS-supported commercial growth in Epsom is being implemented through a large-format retail model where private-vehicle access remains central, even while state and local transport policies seek to minimise car dependency and support sustainable personal transport. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.79-80)

Environmental and Waterway Constraints on Commercial Floorspace

The Epsom case shows that commercial land supply on the Midland Highway corridor is materially shaped by waterway, flooding, and vegetation constraints. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.60-61, 77-82) The site adjoins Racecourse Creek, which converges with Bendigo Creek north-west of the site, and part of the site is affected by Environmental Significance Overlay Schedule 1 and Land Subject to Inundation Overlay Schedule 1. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.60-61) The whole site is affected by Special Building Overlay Schedule 2, which relates to the Bendigo Creek Levee Management area. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.77)

The North Central Catchment Management Authority did not object subject to conditions requiring buildings and works to be set back at least 30 metres from the top of bank of Racecourse Creek and Bendigo Creek, or 5 metres from the toe of the existing earthen levee, whichever is greater. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70, 77) The same referral required no direct stormwater discharge into either creek and specified finished-floor levels for the buildings. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70, 77)

The report states that the existing levee may protect the site from flood events up to and including the 1% annual exceedance probability flood, but that the condition of the levee is unknown and there is no formal arrangement for its management. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.77) That means commercial floorspace delivery in this location depends not only on demand and zoning, but also on flood-free building siting, floor-level controls, water-sensitive drainage design, and external authority consent. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.77-78)

Vegetation constraints also shaped the outcome. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.80-82) The application sought removal of 2 large River Red Gums, equating to 0.141 hectares of native vegetation. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.81) The required offset was 0.025 general habitat units within the North Central Catchment Management Authority or Greater Bendigo City Council areas, with a minimum strategic biodiversity score of 0.136 and including 2 large trees. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.82)

The available evidence therefore points to a commercial-land strategy that requires integration with environmental planning at the site scale. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.77-82) CLACS can identify floorspace demand, but the amount, form, and layout of deliverable floorspace may be reduced or reshaped by waterway buffers, flood levels, levee uncertainty, native vegetation protection, and stormwater detention requirements. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.77-82)

Interface With Huntly and the Northern Growth Corridor

The available source gives one important corridor-scale relationship: Epsom is expected to continue serving residents from Huntly and areas further north in the short to medium term, but that role may change as Huntly’s commercial centre grows. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) This implies that the CLACS activity-centre hierarchy is dynamic rather than fixed. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

The planning mechanism is catchment redistribution. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) If Huntly’s commercial centre grows, some northern-corridor shopping and service trips may shift away from Epsom, which would alter the demand basis for future floorspace assessments in Epsom. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71) The corpus does not contain the Huntly commercial-centre planning documents, so the timing, scale, and policy status of this possible shift cannot be quantified. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

What CLACS Does Not Resolve on the Available Evidence

The available source does not provide CLACS tables, centre-by-centre floorspace numbers, demand methodology, adopted maps, implementation actions, monitoring triggers, or amendment history. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) It also does not provide the Epsom 2031 floorspace forecast value, despite stating that CLACS contains such forecasts. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.71)

The available source does not show whether CLACS nominated preferred locations for restricted retail, bulky goods, office floorspace, neighbourhood retail, or centre-boundary expansion. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-76) It also does not show whether CLACS was implemented through a planning scheme amendment, whether its recommendations remain fully current, or whether it has been superseded in part by later strategies. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-91)

Current Status

The current status of CLACS cannot be fully determined from the available corpus. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The strategy was still being cited in a February 16, 2026 council agenda as a relevant strategic document for Epsom and as the basis for floorspace forecasts to 2031. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The same 2026 report stated that an Epsom structure plan did not exist and was future work, meaning CLACS had not been replaced by a detailed Epsom-specific structure plan at the time of that report. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.70)

Dependencies

  • Blocks: The available source does not show CLACS directly blocking any permit, amendment, or infrastructure project. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-83)
  • Blocked by: Detailed interpretation of CLACS is blocked by the absence of the CLACS 2015 strategy document, Epsom structure-plan work, centre-boundary mapping, and centre-by-centre floorspace tables. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71)
  • Informed by: The available evidence shows CLACS being used with Clause 11.03-1L, the activity-centre hierarchy, population forecasts for Epsom-Ascot, and statutory planning assessment for a Midland Highway restricted-retail proposal. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71)
  • Implements: The available source links CLACS-related assessment to planning policies that focus retail, office employment, community facilities, and services in central locations and support Bendigo’s regional service role. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.88-91)
  • Conflicts with: The available source shows implementation tensions with highway access management, pedestrian and cycling safety, activity-centre boundary uncertainty, waterway and flood constraints, and the absence of an adopted Epsom urban design framework. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-83)

No adjacent-council cross-jurisdictional link is identified in the available source. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-91) The strongest cross-agency links are internal to Greater Bendigo’s planning system and involve the Department of Transport and Planning for Midland Highway access, the North Central Catchment Management Authority for flood and waterway conditions, and the Department of Energy, Environment and Climate Action for Crown land, runoff, and native vegetation matters. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.68-70, 77-82)

Gaps in This Analysis

This analysis is materially constrained because the corpus contains only one agenda report that cites CLACS, not the CLACS 2015 strategy itself. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71) The missing CLACS document is a critical gap because it likely contains the centre hierarchy, floorspace forecasts, methodology, centre maps, implementation recommendations, and monitoring framework needed to assess the strategy at the standard required for a major planning initiative. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-71)

The Epsom structure-plan gap is also critical because the 2026 report states that no Epsom structure plan exists and that this is future work. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, p.70) Without that work, the relationship between CLACS, Epsom activity-centre boundaries, Midland Highway commercial land, public-realm form, access hierarchy, and Huntly’s emerging commercial centre cannot be fully resolved. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-79)

Further missing documents include the CLACS 2015 adopted strategy, any planning scheme amendment that implemented CLACS, Epsom centre-boundary or structure-plan investigations, Huntly commercial-centre planning material, the Public Space Plan 2019, the Greening Greater Bendigo Strategy, and the full technical reports for the 145-157 and 159-165 Midland Highway application. (Source: agendas-and-meeting-minutes-city-greater-bendigo-council-meeting-agenda-february-16-2026.pdf, pp.70-83)

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