Our submission on the State Government’s Activity Centres Program

01 Jul 2025

As a key stakeholder, Merri-bek City Council (Council) welcomes the opportunity to provide feedback on Phase 1 of community engagement for the State Government’s Activity Centres Program (Program).
At this early stage of the Program, Council has not received Activity Centre Plan(s) or any other supporting technical documentation for the Brunswick and Coburg Station Activity Centres (collectively known as the Merri-bek Cluster). This submission provides important high-level feedback based on available information and Council’s close knowledge of the local community

Merri-bek City Council submission

Council is supportive of the State Government’s objective to focus housing growth in well-serviced areas such as the Merri-bek Cluster. Council’s existing total housing capacity across these suburbs is 25,859 (39% of Merri-bek’s capacity), which can accommodate more than 34,000 people by 2051. This growth must be carefully planned to ensure delivery of affordable, sustainable, and diverse high-quality housing supported by essential infrastructure, transport, and open space.

Council has several material concerns with the current approach and asks the Minister for Planning to address these to ensure the accelerated Program does not compromise the liveability of Brunswick and Coburg. It is critical that the Program enables the long-term success of these Activity Centres. Seven key issues are raised below: transport, economy, infrastructure, climate, affordable housing, design quality, and genuine community engagement.

1. Transport

An integrated, accessible and efficient transport system is essential to supporting housing growth and creating liveable communities. However, Merri-bek’s transport network, in particular public transport, is not keeping pace with population growth and evolving travel needs.

Significant increases in housing density without corresponding transport and public transport investment will see liveability standards drop significantly in both Brunswick and Coburg. Brunswick in particular has experienced significant housing development in recent years, but investment in public transport has fallen behind. The Upfield Line is already under significant pressure, and local roads are congested, with many streets operating at or near capacity. By focusing narrowly on housing delivery without corresponding investment in transport infrastructure and services, the State Government’s Activity Centre program is at risk of significantly exacerbating these issues. Challenges include:

  • The bus network is slow, infrequent, and lacks adequate coverage.
  • Tram stops remain largely inaccessible, and trams are frequently delayed in mixed traffic.
  • The Upfield rail line, essential to Melbourne’s northern growth, has limited capacity and infrequent peak-hour trains.
  • Walking and cycling infrastructure also requires improvement. Uneven footpaths, missing links, and steep ramps reduce safety and accessibility.

Council has significant initiatives in train to address local transport priorities, through the Moving Around Merri-bek Transport Strategy (2024) and the “Streets for People” approach which is currently undergoing community consultation. These seek to deliver better local transport and streets as shared, multi-modal spaces that support walking, cycling, and public transport use.

At the State level, Victoria’s Bus Plan (2021) sets out a vision for a modern, productive and sustainable bus network, with simpler, safer and more reliable services. The Plan was to be delivered through a staged Bus Reform Implementation Plan, developed in partnership with industry and the community. However, implementation has not progressed as scheduled.

Key asks

  • To absorb any more housing along this corridor, it is essential that the State Government upgrade critical public transport links and fast track:
  • Duplicating the Upfield line between Gowrie and Upfield.
  • Extending the Upfield line to Craigieburn to enable Wallan V/Line services.
  • Electrifying the Craigieburn–Wallan line to expand capacity and reduce travel times.
  • Deliver a revitalised bus network that better connects people to jobs, education, and services, including preparing and implementing the Bus Reform Implementation Plan as outlined in Victoria’s Bus Plan (2021).
  • Upgrading tram stops and public transport infrastructure to meet overdue 2022 accessibility targets.

It is also vital that the State Government’s Activity Centre Plan for the Merri-bek Cluster:

  • Address walking and cycling infrastructure by identifying missing links, unsafe paths, and connectivity gaps.
  • Increase and improve bike parking requirements alongside any reduction to car parking requirements.

2. Economic growth and employment

Brunswick and Coburg are thriving hubs of creativity, innovation, and economic diversity. Brunswick, in particular, is known for its vibrant arts and culture scene, anchored by the Brunswick Design District and recently enhanced through Council’s $28 million investment in the Balam Balam Place arts hub. RMIT’s design hub adds further strength to the precinct, while a growing cluster of technology and innovation businesses is shaping Brunswick’s future as a key centre for creative industries and knowledge-based jobs.

In Coburg, a mix of retail, professional services, and the city’s iconic jewellery and wedding precinct contributes to a strong and distinctive local economy. Together, these centres reflect Merri-bek’s diverse economic fabric and cultural identity. Ongoing strategic planning is essential to support and expand these dynamic economies—creating more local jobs and promoting inclusive, future-ready economic growth.

Employment in Merri-bek grew from 44,261 jobs in 2021 to an estimated 52,735 in 2023–24, driven largely by population growth and demand for services like health, education, retail, and hospitality. To support continued growth, Merri-bek will require 87,000 to 241,000 square metres of additional employment floorspace by 2035.

However, Council’s 2021 report A Job in Moreland identified that commercial floorspace is being lost through redevelopment, and market delivery remains inconsistent. There is a critical need to retain the role and function of employment land and precincts, and to support the delivery of diverse commercial spaces that meet the needs of a changing economy, particularly in activity centres such as Brunswick and Coburg Station.

To address this, Council consulted with the community on a Planning Scheme amendment to secure commercial floorspace and support Brunswick’s role as a key hub for jobs, services, and housing. Unfortunately, Amendment C230mbek has been awaiting a decision from the Minister for over a year.

Key asks

  • Authorise Amendment C230mbek, which aims to encourage business investment and jobs in the commercial and industrial areas of the Brunswick Activity Centre to ensure the vibrancy of the area does not decline.
  • Ensure that the Activity Centres Plan(s) include an evidence-based and economically viable plan to grow jobs and employment floorspace and ensure no net loss of employment floorspace in the Merri-bek Cluster.

3. Infrastructure

Population growth and development creates increased demand on essential infrastructure such as roads, footpaths, stormwater drains, public open spaces, schools, and community facilities. In high-growth areas like the Brunswick and Coburg Station Activity Centres, this demand is particularly acute and requires timely, coordinated infrastructure delivery.

Responsibility for delivering this infrastructure is shared between developers and all levels of government, including both Local and State Governments. Council is proactively planning for growth and addressing infrastructure needs through a coordinated framework of four proposed amendments to the Merri-bek Planning Scheme. All but one of these amendments are currently awaiting a decision from the Minister for Planning:

  • Applying the new flood controls to properties at risk of flooding from local stormwater drains (Amendment C196mbek).
  • Updating local planning policy to align with Council’s transport and open space strategies (Amendment C231mbek).
  • An increased open space contribution rate to ensure the provision of new public open space in response to growing demand (Amendment C235mbek).
  • A new 15-year Development Contributions Plan to fund key infrastructure (Amendment C236mbek).

Delays in progressing these amendments limit Council’s ability to plan, fund, and deliver critical infrastructure in response to ongoing population growth and development pressures.

To ensure the Merri-bek Cluster grows sustainably and remains liveable, the State Government must also commit to funding and delivering critical State infrastructure, including:

  • Arterial roads, paths, and public transport.
  • New and upgraded public schools.
  • Enhanced health and community facilities.
  • Parks, playgrounds, and sport and recreation spaces.
  • Coordinated investment in broader regional infrastructure.

A clear, streamlined, and collaborative approach across all levels of government is essential to unlock local infrastructure contributions and ensure the timely delivery of state infrastructure that supports vibrant, resilient communities.

Key asks

  • Progress reforms to infrastructure contributions planning mechanisms—including the Activity Centre Infrastructure Contributions Plan—as a priority, to improve fairness, simplicity, and timeliness.
  • Ensure delivery of committed upgrades to public schools, including Coburg High and John Fawkner College, where State-funded works have yet to be completed.
  • Introduce legislative reform to ensure build-to-rent developments contribute fairly to the provision of public open space.
  • Make timely decisions on the three Merri-bek Planning Scheme Amendments currently with the Minister (C231, C235, and C236mbek) to secure essential infrastructure funding for the growing Merri-bek Cluster.

4. Climate adaption and resilience

Merri-bek’s activity centres are already experiencing the effects of climate change. Areas such as the Merri-bek Cluster can be up to 8°C hotter than surrounding suburbs due to low tree canopy cover and high urban density. Several streets within these centres are also vulnerable to overland flooding, with stormwater systems under increasing pressure. Rainfall intensity during short-duration events is projected to rise by over 30% by 2050, amplifying flood risks.

The Activity Centres Program must consider these climate impacts when planning for the Merri-bek Cluster. Intensifying housing in areas already exposed to extreme heat and flooding poses serious risks to community health, safety, and wellbeing. Future growth must be directed to locations that can support climate-resilient and liveable communities.

Environmentally sustainable development

The Merri-bek community has a long-standing commitment to advancing best-practice Environmentally Sustainable Development (ESD). In July 2022, Merri-bek and 23 other councils submitted a group amendment (Amendment C223mbek) to the State Government seeking to elevate sustainability standards in new development. The amendment is still under consideration.

Progress on Amendment C223mbek is increasingly important, as recent changes to state-wide residential design standards may reduce the sustainability outcomes achieved by many councils. Under the new State requirements, average ESD performance in townhouse and apartment developments will materially decline. This will negatively impact both the climate and the liveability standards of future dwellings.

Flooding

Effective water and flood management is essential to sustainable urban growth. Several areas within the Merri-bek Cluster are flood-prone. Council is progressing Amendment C196mbek to apply flood controls to properties at risk of inundation from local stormwater drains. While these controls focus on raising floor levels, they do not guarantee well-designed, flood-resilient buildings. Additional planning guidance is needed to support appropriate building heights, active ground-floor uses, and smooth transitions between raised floors, footpaths, and overall building form.

At the precinct scale, Integrated Water Management (IWM) strategies (such as permeable surfaces, floodable open space, and distributed detention) will be essential for managing more intense rainfall, reducing flood risk, and improving amenity, cooling, and liveability.

Key asks

  • Ensure that the Activity Centre Plan(s) and associated planning controls:
    • Provide strong, consistent ESD and climate response requirements, informed by a Climate Response Plan for the Merri-bek Cluster.
    • Guide building height in areas subject to inundation.
    • Resolve transitional issues between raised floor levels, footpaths, and final building heights.
    • Embed precinct-scale Integrated Water Management (IWM) strategies into the Program.
  • Work with Council Alliance for a Sustainable Built Environment (CASBE) to embed best-practice ESD into the entire State government Activity Centre program.
  • Work with the Metropolitan Melbourne Integrated Water Management (IWM) Forum and the Department of Energy, Environment and Climate Action (DEECA) to embed best-practice IWM Design Guidelines into the Program.
  • Authorise Amendment C223mbek to Merri-bek Planning Scheme.

5. Affordable and diverse housing

While there is a need to increase housing supply, it is equally important that new development delivers an affordable, diverse and accessible range of housing options to meet the evolving needs of our community. Merri-bek has a long-standing commitment to the delivery of diverse housing including social and affordable housing.

Housing diversity and accessibility

As people’s lives change, so do their housing needs. Diverse and accessible housing is essential to creating inclusive, resilient communities. A mix of apartments, townhouses, and detached homes—offered in various sizes, layouts, and tenures—provides choice for people of all ages, incomes, and household types.

Accessible design ensures homes meet the needs of older adults, people with disabilities, and those with temporary mobility challenges. Embedding universal design principles helps ensure housing remains functional and inclusive at every stage of life.

Affordable housing

Merri-bek is experiencing a significant and growing shortfall in affordable housing. As housing costs rise, more households are unable to secure affordable rentals. Current 4,341 households (6.4% of Merri-bek’s population) are unable to access affordable market-priced housing. On current growth and housing supply settings, the number of households in need of subsidised/below-market housing in Merri-bek is predicted to reach 6,800 by 2041. Nearly three-quarters of current jobs in Merri-bek are done by key workers; nearly 4,000 Merri-bek key workers have relocated outside the municipality over the past five years, as a result of housing unaffordability.

Delivery of affordable housing in Victoria is constrained by its reliance on voluntary agreements. This creates uncertainty and places a continuing resource burden on councils, developers, and landowners.

Key asks

Council has long advocated for the State government to introduce mandatory inclusionary zoning to secure affordable housing supply, increase State investment in social housing, and support new affordable housing models through funding, partnerships, and use of public land.

However, in relation to the Activity Centre work in Brunswick and Coburg, Council asks that the Activity Centre Plan(s) and associated planning controls:

  • Include affordable housing requirements.
  • Encourage the integration of universal design to promote flexible, lifelong housing.
  • Support the delivery of larger dwellings in apartment developments, suitable for families and shared households.
  • Encourage a diversity in apartment types to meet a range of lifestyle and household needs.

6. Design quality

Council supports increased housing in the Merri-bek Cluster but emphasises the need for strong built form planning controls to ensure high-quality, well-integrated outcomes, especially on smaller or irregular sites.

Without clear guidance, there is a risk of developments with poor street engagement, limited natural light, and low-quality finishes. Robust design standards can help deliver liveable, attractive, and contextually appropriate buildings.

Council also supports balancing growth with heritage protection, ensuring new development complements the existing streetscape.

Key asks

To provide good development outcomes, the Activity Centre Plan(s) and associated planning controls must:

  • Respond to site conditions including topography, orientation and context.
  • Minimise the dominance of vehicle access and parking and prioritise usable private open space at ground level.
  • Require high-quality materials and finishes.
  • Align with Heritage Overlay objectives to ensure new development respects the location, bulk, form, and appearance of heritage places.

7. Community and Council engagement

The Activity Centres Program will bring significant change and must be guided by clear, inclusive, and ongoing local engagement. A critical component of this is ensuring the notification boundary is broad, logical, and captures all areas directly or indirectly affected by the Program. This includes locations such as eastern Coburg between Bell Street and Moreland Road, which was excluded from the initial engagement without clear justification.

Council expects that the engagement process will provide accessible information, genuine opportunities for input, timely communication, and transparent decision-making that respects local knowledge and builds community trust. These are the same principles Merri-bek applies when undertaking changes to the Planning Scheme, and the community should be afforded the same standard by the State.

Key asks

  • Release all technical information to support transparency, context, and informed participation.
  • Expand the notification boundary to include all affected areas, including the section of eastern Coburg between Bell Street and Moreland Road.
  • Provide timely, accessible materials in plain English and translated formats. This includes the Activity Centre Plan(s) and the draft planning controls.
  • Commit to meaningful community participation. This includes offering more community engagement touchpoints, allowing more time for community and Council to digest proposed changes and prepare submissions, and committing to listen and respond to feedback.
  • Refer submissions to an independent Advisory Committee with public hearings, broad terms of reference, with the Minister for Planning publicly explaining any deviations from its recommendations.

Conclusion

Merri-bek City Council supports well-planned growth in activity centres that reflects local priorities and delivers lasting community benefit. Council looks forward to working with the State Government to achieve these outcomes.