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BRISBANE | MELBOURNE | PERTH | SYDNEY
Water Corporation
Water Efficiency Benchmarks 2017
Retail Buildings – Western Australia
9 March 2018
Water Corporation
Water Efficiency Benchmarks 2017
Retail Buildings – Western Australia
© HFM ASSET MANAGEMENT PTY LTD 2018 i
HFM ASSET MANAGEMENT
HFM Asset Management is a building efficiency company. We are based in Perth, Sydney, Brisbane, Melbourne and
Ballina. Our mission to transform properties into efficient, economic and compliant assets for our clients.
Email [email protected]
Web www.hfmassets.com.au
Telephone 1300 021 420
VERSION CONTROL
VER.
NO.
AUTHOR REVIEWER COMMENT DATE
0.1 Peter Rice Draft 1 02/02/2018
0.2 Peter Rice Draft 2 27/02/2018
1.0 Peter Rice Tayla Knox Final 09/03/2018
This document is prepared for Water Corporation by HFM Asset Management Pty Ltd, is based on assumptions as identified through the text and
upon information and data supplied by others. HFM Asset Management Pty Ltd is not in a position to, and does not verify the accuracy of, or adopt
as its own, the information and data provided by others.
Copyright © 2018 in all of this material vests absolutely in HFM Asset Management Pty Ltd (“the Copyright Owner”). No part of this document or
any of the documents that relate to it may be reproduced, stored in a retrieval system or transmitted in any form or by any means, electrical,
mechanical, photocopying, or otherwise, without the prior written consent of the Copyright Owner.
Water Corporation
Water Efficiency Benchmarks 2017
Retail Buildings – Western Australia
© HFM ASSET MANAGEMENT PTY LTD 2018 ii
CONTENTS
1. INTRODUCTION 1
2. PROJECT SCOPE 2
2.1. PROJECT OBJECTIVES 2
3. DATA SOURCE & SIZE 3
3.1. DATA SOURCE ROADMAP 4
3.2. SUMMARY OF SAMPLE SIZE 4
4. METHODOLOGY 5
4.1. MECHANICAL – AIR-CONDITIONING PLANT 5
4.2. WEATHER 6
5. OUTCOMES 7
5.1. WATER USE TRENDS 7
5.2. TRENDS BETWEEN METRO AND REGIONAL CENTRES 8
5.3. WEATHER RELATED TRENDS 9
6. WATER CONSUMPTION PERFORMANCE CATEGORIES 11
7. RECOMMENDATIONS AND FUTURE BENCHMARKS 12
APPENDIX 13
PROPERTY COUNCIL’S SHOPPING CENTRE CLASSIFICATIONS 13
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FIGURES
Figure 1. Data Source Roadmap. ............................................................................................................................................................... 4
Figure 2. 2017 Water intensity index (kL/m2/year) for buildings greater than 5,000 m2. ........................................................... 7
Figure 3. Water Intensity Index (kL/m2) for each retail building classification, for the last eight years. ................................. 8
Figure 4. Water Intensity Index (kL/m2) – comparison between Metro and Regional Centres. .............................................. 9
Figure 5. Water Intensity Index (kL/m2) – comparison with average maximum temperature for the summer months. 10
Figure 6. Water Intensity Index (kL/m2) – comparison with average maximum temperature for the summer months. 10
Figure 7. Performance Categories. ......................................................................................................................................................... 11
Figure 8. Determination of water consumption benchmarks for the end use water categories. .......................................... 12
TABLES
Table 1. Retail Building Classifications. 3
Table 2. Summary of Sample Size. 4
Table 3. Total Data Set - average water consumption. 7
Table 4. Grange Region - Average water consumption. 9
Table 5. Proposed performance categories and Waterwise program award structure. 11
© HFM ASSET MANAGEMENT PTY LTD 2018 1
1. INTRODUCTION
By request of the Water Corporation, HFM Asset Management participated in a water efficiency benchmarking
exercise for the retail property sector in Western Australia.
The project utilises data derived from the 2010 to 2017 calendar years inclusive. It is designed to provide water
efficiency benchmark guidance to the owners and operators of retail property within Western Australia and establish
a basis to target identified buildings with water efficiency programs. The outcomes may form the basis of a future
Waterwise Shopping Centre Program.
Contributions on this project in relation to data, time and costs were born by the project participants as outlined
below:
Project Participants:
Water Corporation – Provision of annual water consumption data, project co-ordination and the project brief.
Property Council of Australia (WA Branch) – Provision of retail property Gross Lettable Area (GLA) data
greater than 5000 m2, participation in stakeholder consultation and the industry.
HFM Asset Management - Data processing, collation, interpretation, analysis, criteria development, outcome
presentation and report writing.
Stakeholder Workshop Participants:
Water Corporation Kel Medbury
Anna Lichovidova
Senior Advisor – Water Efficiency Programs
Water Efficiency Programs Lead
Property Council of Australia
(PCA)
Lino Iacomella Executive Director (WA)
HFM Asset Management Peter Rice
Bevan Tyler
Engineering Consultant
General Manager
© HFM ASSET MANAGEMENT PTY LTD 2018 2
2. PROJECT SCOPE
The project scope was to develop benchmarking criteria for retail buildings based on data provided by the Water
Corporation and PCA, in consultation with HFM’s experience operating in this space.
Categories of benchmarks were developed for each retail classification. The industry recognised indicator for retail
buildings is water consumption per square meter of gross lettable area (GLA) per annum (kL/m2/annum).
The target group of the study includes sites with a GLA larger than 5,000 m2.
A range of benchmarks have been produced within each category that will determine the level of Waterwise
recognition.
These water consumption performance KPI’s will be based on the benchmark outcomes of the previous calendar year
and hence will change annually. It is envisaged that as the program evolves, and with participation, an incremental
improvement in retail building performance will occur and prompt improvement for consumption baselines and
benchmarks.
2.1. PROJECT OBJECTIVES
The project objectives include:
Identify buildings which are most likely to benefit from targeted water efficiency initiatives.
Develop industry benchmarks which will form the basis of a potential “Waterwise” program.
To motivate and educate sites which have high water consumption in order to improve water efficiency to a
minimum standard.
Reward and recognise those that are leading the industry.
Drive innovation and continued improvement towards best practice.
Retail buildings that meet the minimum set of criteria may be endorsed and receive access to the Waterwise
branding to promote their endorsement.
The “Waterwise” program will be limited to retail buildings that have a Gross Lettable Area (GLA) of greater
than 5000 m2.
© HFM ASSET MANAGEMENT PTY LTD 2018 3
3. DATA SOURCE & SIZE
HFM was provided with total annual water consumption data for calendar years 2010 to 2017 inclusive from the
Water Corporation and was provided with PCA WA gross lettable area (GLA) data for retail buildings within the
Perth metropolitan and Western Australian regional areas.
According to the Property Council’s shopping centre directory, there are six core classifications and four specialist
classifications for shopping centres (Table 1). A full description of each retail classification is provided in the Appendix.
According to the data set, there are no buildings with a gross lettable area retail exceeding 85,000 m2 which is the key
classification for super regional centres. Similarly, of the PCA specialist classifications, only bulky goods centres were
included in the benchmark exercise due to the unavailability of matched data for the other classifications.
Table 1. Retail Building Classifications.
RETAIL BUILDING
CLASSIFICATIONS
TYPICAL GROSS LETTABLE
AREA RETAIL (GLAR) RANGE
INCLUDED IN
BENCHMARK EXERCISE
CORE CLASSIFICATIONS
City Centre > 1,000 m2 Yes
Neighbourhood Centre < 10,000 m2 Yes
Sub-Regional Centre 10,000 < x < 30,000 m2 Yes
Regional Centre 30,000 < x < 50,000 m2 Yes
Major Regional Centre 50,000 < x < 80,000 m2 Yes
Super Regional Centre < 85,000 m2 No
SPECIALIST CLASSIFICATIONS
Bulky Goods Centre > 1,000 m2 Yes
Themed Centre Non-specific No
Market > 5,000 m2 No
Outlet Centre Non-specific No
The annual water consumption and GLA data was processed, collated and categorised in accordance with a data
criterion developed specifically for the context of the project.
© HFM ASSET MANAGEMENT PTY LTD 2018 4
3.1. DATA SOURCE ROADMAP
Figure 1. Data Source Roadmap.
3.2. SUMMARY OF SAMPLE SIZE
Table 2. Summary of Sample Size.
RETAIL BUILDING
CLASS
5’000 –
10’000 m2
10’000 –
20’000 m2 > 20’000 m2 TOTAL
City Centre 1 1 2
Neighbourhood Centre 51 3 54
Sub-Regional Centre 25 12 37
Regional Centre 7 7
Major Regional Centre 8 8
Super Regional Centre
Bulky Goods Centre 1 1 2
All Buildings 53 28 30 110
Water Data
•Water Corporation - annual consumption data
•kL
Area Data
•Property Council GLA data for buildings > 5,000 m2
•m2
Merged Data
•Merged data (120 buildings)
•kL/m2
Filtered Data
•Removal of outliers.
•Filtered data (110 buildings)
Classification
•Retail building classification
•Area and Region classification
© HFM ASSET MANAGEMENT PTY LTD 2018 5
4. METHODOLOGY
The present benchmarking exercise was undertaken as an extension of a similar project undertaken in 2015. The
intent is to develop a set of benchmarks which accurately account for water consumption in retail buildings in the
Western Australian metropolitan and regional areas. The target group of retail buildings are those with a Gross
Lettable Area (GLA) greater than 5000 m2, and with available water consumption data.
Retail buildings and complex’s often exhibit a mixture of retail, commercial office, and other functional uses. Gross
lettable area retail (GLAR) is used to calculate tenancy areas, including supermarkets and speciality retail shops. Gross
lettable area (GLA) is used to calculate tenancy areas which include warehouses, showrooms and office areas
incorporated into a retail complex. The GLA is always equal to or greater than the GLAR.
This benchmarking criteria has been developed using GLA as the denominator and includes all lettable space in the
building; not just retail. This was considered the best approach in order to determine the water intensity index
consistently across the various shopping centres.
PCA GLA (m2) data was available for both the 2014 and 2017 years. Water consumption (kL) data was provided for
the years 2010 to 2017 inclusive. Water readings changed from a frequency of 6-monthly to 2-monthly in 2013 and
therefore from this point onwards there has been an improvement in data validity. The water intensity index (kL/m2)
for the years 2010 – 2014 is based on 2014 GLA data. The water intensity index (kL/m2) for the years 2015 – 2017 is
based on 2017 GLA data.
In the 2015 benchmarking exercise, sites which consumed +/- 50% of the average were excluded, pending further
investigation. The approach in the present exercise was to more closely assess and consider each site for exclusion
from the database. Following calculation of the annual water intensities, every property was considered for inclusion
into the database. Excessively high and low consumers were excluded based on a range of factors, including non-
validated data as well as large non-retail water end uses. We believe that this approach more effectively assesses the
current trends in the retail building stock and also identifies the buildings most applicable for strategic targeting of
water efficiency initiatives.
The above methodology produced a final filtered data set of 110 retail buildings upon which analysis was undertaken.
As this process continues to evolve over the coming years, the filter and data quality will improve and as well as the
related accuracy of associated benchmarks.
4.1. MECHANICAL – AIR-CONDITIONING PLANT
Within the present benchmark analysis, it was not feasible to consider the mechanism of air conditioning as a
benchmarking variable. This is due to the fact that retail buildings often consist of a mixture of air-conditioning
systems and types.
Historically when developers have planned the development or expansion strategy of a retail establishment, water
efficiency is not a key driver, but rather a by-product of the building services deployed to meet the properties
requirements. This disparity exists in retail centres across all categories. As a result, retail buildings will often
incorporate a hybrid arrangement of air cooled and water-cooled solutions deployed centrally or by individual tenants.
The variance in mechanical plant and equipment deployed within a centre may consist of a combination of the
following system types:
Water cooled central plant
– Cooling towers
– Evaporative condensers
– Air cooled supplemented with adiabatic cooling.
Air cooled central plant
Packaged refrigerated air-cooled systems
Split type refrigerated air-cooled systems
© HFM ASSET MANAGEMENT PTY LTD 2018 6
Evaporative air-conditioner
Therefore, due to the variance of systems deployed in properties within the dataset, for the purpose of this study it is
not practically feasible to separate water-cooled centres from air cooled centres (as successfully undertaken within
the commercial office Waterwise benchmarking analysis project), because most centres include a combination of both.
If in the future, steps are taken to facilitate detailed documentation of the extent of separation of end use services that
utilise water within retail centres; this information will become more readily available. This will be achieved via the
deployment of improved sub-metering practices to significant end uses.
4.2. WEATHER
Weather is also a variable which affects water consumption at retail centres in Western Australia. Shopping centres
with water-cooled plant are more likely to use more water to aid heat rejection during hot times of the year.
Additionally, landscape irrigation consumption is more likely to be higher in periods of hot weather.
During this exercise, the correlation between water consumption and changes in the weather was tested by
comparing:
Average annual water consumption (kL/m2) vs. Average maximum summer temperature (⁰C),
Average annual water consumption (kL/m2) vs. Sum of Cooling Degree Days (CDDs) for each annual period.
Cooling Degree Days (CDDs) indicate the level of comfort and are based on the average daily temperature. The
average daily temperature is calculated as follows: [maximum daily temperature + minimum daily temperature] / 2.
If the average daily temperature is above comfort levels, cooling is required. CDDs are determined by the difference
between the average daily temperature and the BASE (comfort level) temperature. The BASE values used are 18 and
24⁰C for cooling. Therefore, the CDD is the number of degrees that that the average daily temperature is above
24⁰C.
It is hypothesised that there will be a correlation between water consumption and summer temperature.
© HFM ASSET MANAGEMENT PTY LTD 2018 7
5. OUTCOMES
The project has revealed water consumption averages and trends across the past eight years for retail buildings within
Western Australia. Subsequently, industry benchmarks may be developed as the basis of Waterwise initiatives
specifically tailored to this sector.
Figure 2 presents the water intensity index (kL/m2) for the 2017 calendar year. Each building is ranked from most
efficient to least efficient, with the average water intensity index calculated as 1.021 kL/m2 for this period. The
distribution of data points in each year follows the same pattern as below. The data points are distributed in a
common probability distribution (normal distribution) around the average (mean) water intensity index.
Figure 2. 2017 Water intensity index (kL/m2/year) for buildings greater than 5,000 m2.
5.1. WATER USE TRENDS
The water consumption trend over the past eight years is shown in Table 3 for each retail building classification.
Table 3. Total Data Set - average water consumption.
RETAIL
CENTRE
CLASS
SAMPLE 2010 2011 2012 2013 2014 2015 2016 2017
City Centre 2 0.48 0.32 0.40 0.36 0.33 0.32 0.55 0.52
Neighbourhood 54 1.43 1.36 1.34 1.24 1.20 1.22 1.17 1.11
Sub Regional 37 1.11 1.09 1.08 1.11 1.11 1.05 1.13 1.07
Regional 7 0.96 1.04 1.10 0.96 1.01 0.93 0.95 0.91
Major Regional 8 1.17 1.21 1.15 1.20 1.15 1.17 1.22 1.09
Bulky Goods 2 0.62 0.57 0.48 0.48 0.49 0.54 0.45 0.33
All Buildings 110 1.22 1.19 1.17 1.14 1.12 1.11 1.12 1.06
The trend is a reduction in the average water consumption for retail buildings over the last eight years, illustrated in
Figure 3 below. Observations from the data include:
Neighbourhood Centre’s have the largest sample size (54 buildings) and have demonstrated a significant average
water intensity index reduction of 0.046 kL/m2 per year.
The larger Sub-regional centres (37) have only reduced marginally in comparison.
The small sample size of City Centre (2) and Bulky Goods (2) means the average water intensity index is easily
impacted by individual site performance.
0
0.5
1
1.5
2
2.5
3
3.5
Water
Intensity
(kL/m2)
© HFM ASSET MANAGEMENT PTY LTD 2018 8
Regional Centres are more water efficient compared to Major Regional Centre’s and both retail classes have
demonstrated inconsistent consumption over the past eight years.
Overall, the average water intensity index has decreased for the WA retail building stock; reducing by 0.16 kL/m2
(-13.1%) over the past eight years. This corresponds to a cumulative water volume decrease of 1.29 GL.
Figure 3. Water Intensity Index (kL/m2) for each retail building classification, for the
last eight years.
The outcomes identify that water usage patterns are changing within the Western Australian retail building sector. It is
clear that trends exist for each classification and that these are influenced by factors such as plant type, management
intensity, irrigation requirements, and maintenance practices which likely vary with respect to building size and
function. This prompts the requirement to better understand why these differences exist and what bearing they have
on building water efficiency.
5.2. TRENDS BETWEEN METRO AND REGIONAL CENTRES
Apart from centre types, variances between metropolitan and regional centres were also examined. The data analysis
is presented in Table 4 and Figure 4. Observations from the data are summarised below:
Out of the 110 retail properties, 94 were located in the Perth region.
There is a strong correlation between the water intensity index and climate.
Properties located in the North West have the highest water intensity index.
Properties located in the South West and Great Southern have the lowest water intensity index.
The water intensity index for the 5 North West properties has decreased over the past eight years.
0.0
0.1
0.2
0.3
0.4
0.5
0.6
0.7
0.8
0.9
1.0
1.1
1.2
1.3
1.4
1.5
2010
2011
2012
2013
2014
2015
2016
2017
Water
Intensity(kL/m2)
Bulky Goods City Centre Neighbourhood
Major Regional All Buildings Sub Regional
Regional
© HFM ASSET MANAGEMENT PTY LTD 2018 9
Table 4. Grange Region - Average water consumption.
GRANGE
REGION
SAMPLE
SIZE
2010 2011 2012 2013 2014 2015 2016 2017
Goldfields 1 1.04 0.97 1.00 1.31 0.88 1.08 1.25 0.88
Great Southern 4 0.93 0.94 0.84 0.59 0.53 0.58 0.50 0.68
Mid West 3 1.11 1.12 1.03 1.03 0.98 0.94 0.98 0.98
North West 5 1.72 1.79 1.50 1.55 1.37 1.47 1.34 1.42
Perth 94 1.22 1.17 1.18 1.15 1.14 1.13 1.16 1.07
South West 3 0.38 0.72 0.94 0.67 0.78 0.51 0.66 0.79
Figure 4. Water Intensity Index (kL/m2) – comparison between Metro and Regional
Centres.
5.3. WEATHER RELATED TRENDS
There is a relationship between weather and water consumption. The figures below demonstrate the trends observed
over the past seven years with respect to the average summer maximum temperature (Figure 5) and annual cooling
degree days (Figure 6) respectively.
There is a positive correlation between the water intensity index and average summer maximum temperature, with a
correlation coefficient of 0.63. The relationship between water intensity index and annual cooling degree days shows a
correlation coefficient of 0.71. These values indicate a degree of dependence between weather and water
consumption with more water consumed during warmer years. Although there is a correlation between these
variables, a causal relationship cannot be inferred (i.e. there are other variables affecting the water intensity index
apart from weather).
The key water end uses that are expected to increase with respect to higher temperature and CDD include;
Landscape irrigation,
Water-cooled mechanical plant, and;
0.3
0.5
0.7
0.9
1.1
1.3
1.5
1.7
1.9
Water
Intensity
(kL/m2)
Goldfields Great Southern Mid West
North West South West Perth Region
© HFM ASSET MANAGEMENT PTY LTD 2018 10
Water features.
It is an acceptable conclusion to draw that ambient weather conditions impact water consumption to a certain extent.
Other variables include occupancy and patronage, as well as water efficiency improvements and awareness in retail
centres.
Figure 5. Water Intensity Index (kL/m2) – comparison with average maximum
temperature for the summer months.
Figure 6. Water Intensity Index (kL/m2) – comparison with average maximum
temperature for the summer months.
1.00
1.02
1.04
1.06
1.08
1.10
1.12
1.14
1.16
1.18
1.20
29.0
29.5
30.0
30.5
31.0
31.5
32.0
32.5
33.0
2011
2012
2013
2014
2015
2016
2017
Water
Intensity (kL/m2)
Temperature
(°C)
Average Maximum Temperature (Summer) Average Water Consumption (kL / m2)
1.00
1.02
1.04
1.06
1.08
1.10
1.12
1.14
1.16
1.18
1.20
0
20
40
60
80
100
120
140
160
180
200
220
240
260
280
300
3202011
2012
2013
2014
2015
2016
2017
Water
Intensity (kL/m2)
Annual
Cooling Degree
Days
Annual Cooling Degree Days Average Water Consumption (kL / m2)
© HFM ASSET MANAGEMENT PTY LTD 2018 11
6. WATER CONSUMPTION PERFORMANCE CATEGORIES
Water use baselines and performance categories have been developed for the potential development of a Shopping
Centres Waterwise Award Program.
Each property was sorted into the performance categories as defined in Table 5, and as established in the 2015
version of this report. There are seven performance categories, of which the upper five correspond to a Waterwise
award category.
Table 5. Proposed performance categories and Waterwise program award structure.
PERFORMANCE
CATEGORY
WATER INTENSITY
INDEX
WATERWISE
AWARD
STRUCTURE
SAMPLE SIZE
(2017)
Poor >1.56
Participant Certificate
18
Below Average 1.16 - 1.56 17
Baseline 0.96 - 1.16 13
Average 0.76 - 0.96 Bronze 28
Above Average 0.56 - 0.76 Silver 18
Best Practice < 0.56 Gold 15
Top Performer Best annual verified outcome Platinum 1
Figure 7. Performance Categories.
It is identified that these performance categories should form the initial basis of the Waterwise rewards program for
retail buildings in Western Australia. Shopping centres are changing their water use over time, as evident by the
decreasing baseline across the past eight years. Following implementation, the performance category may be revised
to reflect these changes and encourage best practice performance.
-
0.50
1.00
1.50
2.00
2.50
3.00
3.50
Water
Intensity
Index
(kL/m2)
© HFM ASSET MANAGEMENT PTY LTD 2018 12
7. RECOMMENDATIONS AND FUTURE BENCHMARKS
The utilisation of the benchmark database to target identified buildings with water efficiency initiatives is
recommended. This is likely to assist in improved performance for the worst performing buildings and as a result
improve the overall performance of the stock. Next steps may include desktop analysis of data logger information or
site-based water audits for targeted buildings.
The key to driving water efficiency in retail centres, or any facility for that manner, is in delivering a better
understanding of the end uses and usage patterns within the facility.
Ultimately, the best practice management of water consumption should include monitoring of key end uses. Hence it
is our recommendation that the Waterwise retail program has a future target to develop detailed performance
criteria, utilising predetermined sub-metering for subsets of water end uses.
It is envisaged this methodology could drive water efficiency practices in retail buildings and deliver step change water
usage reductions across the sector.
A sample of what this may look like is outlined below:
Figure 8. Determination of water consumption benchmarks for the end use water
categories.
© HFM ASSET MANAGEMENT PTY LTD 2018 13
APPENDIX
PROPERTY COUNCIL’S SHOPPING CENTRE CLASSIFICATIONS
a. Core Classifications
i. City Centre
Retail premises within an arcade or mall development owned by one company, firm or person and
promoted as an entity within a major Central Business District.
Total GLAR exceeds 1,000 square metres.
ii. Super Regional Centre
A major shopping centre typically incorporating two full line department stores, one or more full line
discount department stores, two supermarkets and around 250 or more specialty shops.
Total GLAR exceeds 85,000 square metres.
iii. Major Regional Centre
A major shopping centre typically incorporating at least one full line department store, one or more full line
discount department stores, one or more supermarkets and around 150 specialty shops.
Total GLAR generally ranges between 50,000 and 85,000 square metres.
iv. Regional Centre
A shopping centre typically incorporating one full line department store, a full line discount department
store, one or more supermarkets and around 100 or more specialty shops.
Total GLAR typically ranges between 30,000 and 50,000 square metres.
In some instances, all other characteristics being equal, a centre with two full discount department stores,
without a department store, can serve as a regional centre.
v. Sub-Regional Centre
A medium-sized shopping centre typically incorporating at least one full line discount department store, a
major supermarket and approximately 40 or more specialty shops.
Total GLAR will typically range between 10,000 and 30,000 square metres.
vi. Neighbourhood Centre
A local shopping centre comprising a supermarket and approximately 35 specialty shops.
Total GLAR will typically be less than 10,000 square metres.
b. Specialist Classifications
i. Bulky Goods Centre
A medium to large sized shopping centre dominated by bulky goods retailers (furniture, white goods and
other homewares) occupying large areas to display merchandise. Typically contain a small number of
specialty shops.
Total GLAR will typically be greater than 5,000 square metres.
ii. Themed Centre
A speciality shopping centre, located primarily in resort areas to cater for specialist tourist needs, which
does not normally include a supermarket.
© HFM ASSET MANAGEMENT PTY LTD 2018 14
iii. Market
A covered centre of at least 5,000 square meters dominated by food retailing with at least 50 stalls or
outlets. It operates on a permanent or irregular basis.
iv. Outlet Centres
A medium to large sized shopping centre which does not normally include a department store, discount
department store, or supermarket.