title: “Amendment C221ball — Growth Area UGZ Rezoning” council: ballarat state: vic category: amendment classification: MAJOR status: partially-resolved lifecycle_stage: Core area gazetted via Ministerial amendment (22 June 2023); Expanded Area and Western/NW rezonings unresolved; superseded in substance by Ministerial-led PSP/DCP process (C258ball package) last_compiled: 2026-04-16 source_docs:

23-february-2022-council-meeting-agenda-with-attachments_part1.txt
d-22-28671-23-february-2022-council-meeting.txt
22-june-2022-council-meeting-agenda-with-attachments.txt
14-december-2022-council-meeting-agenda-with-attachments.txt
26-april-2023-council-meeting-agenda-with-attachments_1.txt
23-august-2023-council-meeting-agenda-with-attachments_part2.txt
13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt
27-march-2024-council-meeting-agenda-with-attachments.txt
26-june-2024-council-meeting-agenda-with-attachments.txt
11-september-2024-council-meeting-agenda-with-attachments-compressed_part8.txt
11-december-2024-council-meeting-agenda-with-attachments.txt
11-december-2024-council-meeting-minutes.txt
24-september-2025-council-meeting-agenda-with-attachments.txt
growth-areas-framework-plan-western-and-north-western-growth-areas_august-2024.txt

Amendment C221ball — Growth Area UGZ Rezoning

Amendment C221ball was the vehicle through which the City of Ballarat proposed, in February 2022, to rezone approximately 2,582 hectares of fringe rural land across three growth fronts — Northern (722 ha), Western (1,170 ha) and North-Western (690 ha) — to the Urban Growth Zone (UGZ), and to insert a new “Housing Framework Plan” local policy to support staged PSP preparation (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt). The amendment never proceeded in the form Council resolved. Instead, the Minister for Planning used Section 20(4) of the Planning and Environment Act 1987 in September 2022 to authorise DELWP (now DTP) to prepare a separate, expedited Ministerial amendment that rezoned only the “core” of the Northern Growth Area in June 2023, quarantined the “expanded” portion of the north, and declined to rezone the Western and North-Western growth fronts at all, instead redirecting them through a sequential VPA-led “Infrastructure Growth Alignment Framework” (IGAF) and a Council-led Growth Areas Framework Plan (GAFP) process. C221ball is therefore a partially-resolved amendment: its northern objective was delivered statutorily through a substitute pathway; its western and north-western objectives remain stranded at authorisation stage, dependent on strategic sequencing decisions that only began to become concrete when the GAFP was adopted on 14 August 2024 (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt). Understanding C221ball is understanding the Ballarat greenfield land-supply system: it is the instrument that created the “core vs expanded” dichotomy of the Ballarat North Growth Area, generated the IGAF commissioning, produced the GAFP, and remains the structural precursor to the currently exhibiting Ballarat North PSP/DCP package (exhibition opened 19 September 2025, PSP gazettal targeted for mid-2026).

This page treats C221ball as a MAJOR initiative. It is the largest single rezoning proposal in Ballarat’s planning history since the Ballarat West growth area was zoned in the 2010s; it affects Council’s 20-year land supply; it triggers infrastructure contributions planning across three growth fronts; and it has driven Ministerial, departmental (DELWP → DTP), and VPA engagement continuously for four years.

Background

The problem C221ball was written to solve

From 2018 onward, City of Ballarat officers worked through the Ballarat Long Term Growth Options Investigation to identify the next greenfield land supply beyond the existing ballarat-west-psp (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt). By 2021, the arithmetic had become urgent:

Ballarat’s population was estimated at 113,700 in 2021 (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, Table 1).
At the 2.5%/annum benchmark growth rate used by Council, Ballarat was projected to grow to 185,000 by 2040/41 — an increase of 72,611 persons requiring approximately 29,000 additional dwellings, or 1,450 dwellings per year across the municipality (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 35).
Building approvals in the Ballarat West PSP area had escalated from approximately 500 dwellings/year in 2018/19 to over 1,200/year in 2020/21, with 1,800 dwellings anticipated for completion in 2021/22 (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 39).
At that burn rate, Ballarat West (Council’s only greenfield growth area) was forecast to have only approximately 6,000 lots remaining by 2024/25, by which time alfredton-west-psp would also be effectively built out (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 43).
Without additional greenfield zoning, “growth area supply will effectively exhaust from 2025-26 from when lot production per year will decrease significantly to the low 100s per year” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 44).

The supply cliff implied by these numbers — a drop from ~1,800 completions/year to “the low 100s” within three to four years — is the core fact that makes C221ball a MAJOR initiative rather than an administrative rezoning. The amendment was the statutory trigger Council needed to stop Ballarat’s greenfield supply from cliff-diving.

The 23 February 2022 Council resolution (R14/22)

On 23 February 2022, moved by Cr Ben Taylor and seconded by Cr Peter Eddy (Source: d-22-28671-23-february-2022-council-meeting.txt, p.22), Council carried Resolution R14/22 directing officers to:

Apply to the Minister for Planning under Section 8A(2) and (3) of the Planning and Environment Act 1987 for authorisation to prepare Amendment C221ball, comprising:
- (a) rezoning of the growth areas to the Urban Growth Zone in accordance with Attachments E (Northern), F (Western) and G (North-Western) to the 23 February 2022 meeting report (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 72.1, 18645–18647);
- (b) a policy amendment introducing a new “Housing Framework Plan” to support the next phases of planning (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.1(b)).
If authorised, exhibit the amendment under Section 19 notice requirements (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.2).
Commence preparation of a PSP for the northern growth area following UGZ application (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.3).
Note that the Ballarat Housing Strategy should ultimately be the mechanism to determine the extent of future growth and infill development (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.4).
Authorise the Director Development and Growth to make minor changes to the amendment documentation (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.5).
Note that a Growth Areas Framework Plan would be prepared to establish PSP sequencing for the western and north-western areas, aligned to sustainable development principles and planned infrastructure (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.6).
Report back quarterly on rezoning progress and GAFP timeframes (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.7).

The resolution was preceded by Resolution R13/22 (moved Cr Daniel Moloney, seconded Cr Samantha McIntosh) which dealt with upstream strategic policy matters, and followed by Cr McIntosh calling for a report to Councillor Briefing regarding “processes in place to ensure” proper governance of the amendment (Source: d-22-28671-23-february-2022-council-meeting.txt, pp.21–22).

The statutory shape of what was proposed

C221ball proposed two interlocking statutory changes:

Zone change. The Urban Growth Zone (Clause 37.07 of the Victoria Planning Provisions) is the zone used across metropolitan Melbourne’s growth corridors and selected regional growth fronts. It differs from the Farming Zone or Rural Living Zone that covered most of the C221ball land in that it:

explicitly anticipates urban development once a PSP is in force,
prohibits subdivision for standard lots until an applied UGZ schedule (UGZ1, UGZ2, etc.) is in place referencing an incorporated PSP,
preserves existing use rights until development triggers are met,
effectively freezes speculative rural subdivision and informal land use intensification while the PSP is prepared.

Applying the UGZ is therefore itself an interim land-use control with material financial consequences for landowners: it legally signals development potential without conferring immediate development rights.

Local policy insertion. The “Housing Framework Plan” (referred to in some 2022 documents as the “Housing Change Framework Plan”, Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 10(a)) would have been inserted into the Ballarat Planning Scheme’s Planning Policy Framework (post-VC148 scheme structure). Its function: provide the spatial logic justifying the UGZ boundaries and cueing future PSP preparation. This policy amendment component has not been delivered through C221ball; the Growth Areas Framework Plan adopted 14 August 2024 now serves this function, and its incorporation into the planning scheme is a separate (distinct) amendment pathway yet to be authorised (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 17).

Policy framework justification

C221ball was positioned by Council as consistent with:

Clause 21.02-4 of the Ballarat Planning Scheme — requires greenfield development to be “focused within roughly 8km arc from the centre of Ballarat in line with the Compact City and 10-minute City strategic direction”, to avoid ad-hoc development, discourage “leapfrog” development, minimise impacts on Ballarat’s historic urban landscape, and ensure buffers to water/sewerage assets (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 27).
Ballarat Strategy 2040 (City of Ballarat 2015) — emphasising “considered growth across the City” with infill carrying importance for neighbourhood vibrancy and services viability (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 24).
DELWP Planning Practice Note 90 — requires local authorities to plan for at least 15 years of projected population growth and to consider residential land supply on a municipal rather than town-by-town basis (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 30).
DELWP Urban Development Program (UDP) methodology — the state-endorsed approach for calculating supply, as distinct from developer sales-based estimates (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 42).

This framing matters because the Minister’s subsequent decision to bifurcate the amendment — rezoning the north but not the west or north-west — pivoted on whether the strategic justification was sufficient for each front. For the Western and North-Western fronts, the Minister effectively concluded that additional infrastructure sequencing analysis (the IGAF and the GAFP) was required before UGZ application could be justified at a state level.

Analysis

1. Land supply arithmetic: what C221ball was meant to unlock

The February 2022 report presented a land budget and yield analysis for each of the three growth areas. This table, reproduced here from Table 2 of the officer’s report (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 65–67):

Growth Area	Gross Developable Area (ha)	Estimated Net Developable Area (ha)	Indicative yield @15 dw/ha NDA	Indicative population @2.5 persons/dw
Northern (recommended boundary)	722	376 (+ low-density areas noted)	6,190 dwellings	15,475 persons
Western (recommended boundary)	1,170	896	13,440 dwellings	33,600 persons
North-Western (recommended boundary)	690	500	5,000 dwellings	12,500 persons
Combined	2,582	1,772	24,630 dwellings	61,575 persons

Several features of this table matter for understanding the amendment’s stakes:

(a) The Northern Growth Area’s NDA ratio is anomalous. 376 ha NDA out of 722 ha gross = 52% developable, well below the ~76% Western and ~72% North-Western ratios. The report notes this arises because the Northern Growth Area contains the Mount Rowan landscape feature (flagged as requiring “detailed landscape assessment as part of the future structure planning process to ensure its ongoing protection as a significant natural feature protected from development”), the Burrumbeet Creek corridor and environs on the western boundary, and interface transitions to the Dowling Forest Racecourse and Equine Precinct to the north and to Rural Living areas (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 49, 51, 52). The low developable yield is therefore not a drafting artefact but a structural constraint — Mount Rowan is effectively off-limits for residential development.

(b) The 15 dw/ha assumption is conservative by recent Victorian greenfield standards. Contemporary regional greenfield PSPs commonly assume 16–20 dw/ha (the Ballarat West PSP area averages around 15 dw/ha; recent Melbourne growth areas target 18–22 dw/ha). A 15 dw/ha assumption implies a lower lot yield but also creates headroom: if PSPs ultimately deliver at 18 dw/ha, the Northern Growth Area’s 376 ha NDA could yield approximately 6,768 lots rather than 6,190 — an additional ~580 lots without boundary change.

(c) 2.5 persons/dwelling is the 2016 Census average. This was explicitly flagged as the assumption basis (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, Table 1). The 2021 Census average for Ballarat is approximately 2.4 persons/dwelling, reflecting smaller household sizes — applying 2.4 reduces projected population capacity by ~2,460 persons across the three areas.

(d) The combined capacity (24,630 dwellings) closely matches the 20-year demand. Council’s own analysis projected demand of approximately 1,450 dwellings/year municipality-wide (1,000+ of which must be accommodated in growth areas). 20 years × 1,000 = 20,000 growth-area dwellings required. The C221ball yield of 24,630 dwellings therefore provides approximately 24 years of supply at that burn rate, plus the 6,000 residual lots in Ballarat West through to ~2027–28 — i.e., the amendment was calibrated to provide a 20–25 year greenfield horizon. Removing the Western and North-Western fronts from the amendment (as the Minister effectively did) truncates this to ~6 years (Northern only: 6,190 dwellings ÷ 1,000 dw/year = 6.2 years).

(e) The “effective NDA” after PSP-stage constraints will be lower. The February 2022 table was pre-PSP. PSP-stage constraints typically reduce headline NDA by 15–30%: drainage infrastructure land take, transport corridor reservations, heritage curtilages, bushfire setbacks, active and passive open space, and community infrastructure sites. For the Ballarat North Growth Area specifically, the subsequent VPA technical work has identified adverse amenity constraints around existing industry (Source: vpa-ballarat-north-psp-adverse-amenity-impact-assessment-ghd.-may-2024.txt) and further drainage and cultural heritage constraints noted in the innovation pathway deliverables. A realistic lot yield after PSP refinement is therefore likely to be in the range 5,000–5,800 lots for the core Northern area, not 6,190.

2. The Northern Growth Area — what C221ball proposed and what actually happened

The originally proposed Northern Growth Area boundary (pre-Ministerial intervention)

The February 2022 Northern Growth Area boundary extended further than the original “Growth Investigation Area” identified in the 2020 consultation (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 49). Council’s justification:

Physical containment: the area is “bounded by the Western Highway to the south, the Midland Highway to the east, the Burrumbeet Creek and environs to the west” with transitional treatment at the Dowling Forest Racecourse/Equine Precinct boundary to the north (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 49).
Locational logic: “close synergies to the Miners Rest township to its immediate west and Ballarat to its south, notwithstanding being physically separated by the Western Highway and Burrumbeet Creek” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 50).
Distinct from Ballarat West in character: “distinctly different to Ballarat West in its residential development offering given its natural characteristics, location and setting” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 50).
PSP sequencing logic: Council recommended a separate PSP for the north ahead of the western areas because “the northern growth area supports the continuation of housing stock within the growth areas as a transition from the current Ballarat West Precinct Structure Plan area”, “key agencies endorse the prioritisation of the northern growth area”, and because “a large percentage of the growth area is controlled by a development partnership and therefore does not require a broader Framework Plan to ensure logical sequencing” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 53).

The phrase “controlled by a development partnership” is operationally important: it implies a single or small consortium of landowners prepared to coordinate delivery, fund third-party PSP costs, and negotiate a DCP. This is the landowner typology that makes VPA-led PSP delivery feasible without a competing-interests panel hearing on basic boundary questions. Council’s subsequent quarterly updates confirm that “third-party funding agreements with landowners to fund the preparation of technical reports and planning documents” have been progressing through the VPA (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 16).

The Ministerial bifurcation — 6 September 2022 letter

On 6 September 2022, the City of Ballarat received correspondence from the Minister for Planning authorising DELWP “to prepare, adopt and approve an amendment to rezone the core area of the Northern Growth Area and to make the policy changes to the Ballarat Planning Scheme” (Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 4). This is the pivotal moment in C221ball’s history. The Minister’s decision did three things:

Split the Northern Growth Area into “core” and “expanded” components. The Minister agreed to rezone only the core — the extent that matches approximately the original Growth Investigation Area — and directed that the expanded area (the additional land Council had added in its February 2022 recommended boundary) be subject to “further investigation” before rezoning (Source: 23-august-2023-council-meeting-agenda-with-attachments_part2.txt, para 5).
Substituted the statutory vehicle. Rather than proceed as Council’s C221ball amendment (which would have required Council-led exhibition under Section 19), the Minister directed DELWP to prepare a separate Ministerial amendment — ultimately gazetted as C258ball in the core area rezoning process. C221ball therefore became a “parent proposal” whose core-area objective was delivered by substitute, not by itself.
Appointed the VPA as Planning Authority for the Northern PSP and DCP. The Minister concurrently appointed the Victorian Planning Authority (VPA) to be the planning authority to prepare the Northern PSP, the DCP, and the implementing planning scheme amendment (Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 6). This transferred the statutory lead role from Council to VPA — a significant governance shift because VPA-led PSPs follow the VPA’s Planning Practice Note templates (transport, drainage, open space, affordable housing, culturally sensitive design) and report to the VPA Board before the Minister.

Council’s December 2022 report summarised the Minister’s directive with four bullet points: “DELWP to rezone Core Northern Growth Area to an Urban Growth Zone; DELWP to update the Ballarat Planning Scheme; VPA to prepare the PSP for the Northern Growth Area; VPA to review Ballarat’s greenfield land and urban renewal areas land supply as part of the HLSR [High-Level Strategic Review, later renamed IGAF]” (Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 10).

Core rezoning gazettal — 22 June 2023

On 22 June 2023, DTP (the Department of Transport and Planning, into which DELWP’s planning functions had moved following the 2022 machinery-of-government change) confirmed that “an amendment to rezone the core area of the Ballarat Northern Growth Area (BNGA) to the UGZ had been approved” (Source: 23-august-2023-council-meeting-agenda-with-attachments_part2.txt, para 4). This confirmation — approximately nine months after the 6 September 2022 authorisation letter — marks the date on which the core area changed from Farming Zone/Rural Living Zone to UGZ under the Ballarat Planning Scheme.

The rezoning itself was effected by a Ministerial amendment (not by Council’s C221ball), so the usual C221ball exhibition/submissions/adoption pathway never occurred for the core. No Section 19 notice was given. No public submissions were received on the zone change. No Panel was convened. This is the characteristic of a Section 20(4) expedited Ministerial amendment — exempt from notice — and it is why C221ball, in its originally-authorised form, never went to exhibition.

This matters for the development feasibility analysis: the statutory certainty of the core UGZ is now in force, but the landowners and Council cannot rely on C221ball itself as the statutory precedent. Any future reference to “the zone change” must cite the Ministerial amendment gazettal, not R14/22.

The “Expanded Area” — quarantined since 2022, abandoned in late 2024

The February 2022 Council boundary included land beyond the core Growth Investigation Area. The Minister’s September 2022 decision quarantined this expanded area pending “further investigation by the VPA before it can be rezoned” (Source: 23-august-2023-council-meeting-agenda-with-attachments_part2.txt, para 5; 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 5).

Over 2023 and 2024 the VPA commissioned technical background reports that, in the official quarterly updates, were consistently described as “also assess the merits of the expanded area” (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 6; 27-march-2024-council-meeting-agenda-with-attachments.txt, para 6). These reports — Integrated Water Management, Historical Heritage, Land Capability Assessments — were framed as the evidentiary base on which the expanded-area decision would be made.

The 11 December 2024 quarterly update recorded a decisive conclusion: “It has since been confirmed that the VPA’s position is to not include the expanded area in the PSP” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 8). This is the critical sentence. In a single line in a quarterly update, the VPA’s position on the expanded area — unresolved for 27 months since the 6 September 2022 authorisation letter — was finalised against inclusion.

Implications of the expanded-area exclusion:

The 722 ha / 376 ha NDA figure for the Northern Growth Area in C221ball’s original proposal included the expanded area. The remaining “core” area is smaller. Publicly available mapping (Source: 23-august-2023-council-meeting-agenda-with-attachments_part2.txt, Figure 1: BNGA Rezoned UGZ and Investigation Land) suggests the core is perhaps 60–75% of the original Council boundary, though exact hectarages for the core alone are not cited in the quarterly updates in the corpus. A conservative assumption is that the core delivers approximately 280–330 ha NDA, implying ~4,200–5,000 lots at 15 dw/ha, rather than the 6,190 originally projected.
Landowners in the expanded area retain Farming Zone / Rural Living Zone controls. They cannot rely on UGZ-based development uplift. Their land remains held for “further investigation” without a published timeline or a stated pathway for review of the VPA’s not-included position.
Infrastructure capacity modelled in the PSP/DCP will only need to service the core, not the expanded area. This reduces the DCP levy base but also reduces the infrastructure cost the DCP must recover.
If, at a later stage, Council (or landowners) seek to bring the expanded area back into scope, the statutory vehicle is unclear: C221ball is the authorised parent proposal but it has been overtaken by the Ministerial amendment process. A fresh authorisation under Section 8A, or a Ministerial Section 20(4), would likely be required.

Innovation Pathway — the soft-policy substitute for the expanded area

Parallel to the boundary question, Council applied in July 2022 to the VPA’s “Innovation Pathway” pilot program, “a pilot program to encourage significant innovations in a PSP that might otherwise be difficult to achieve due to policy and practice constraints” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 4). In February 2023, the VPA Board selected the Ballarat North PSP project “as the successful pilot PSP to test planning and design of desired sustainability outcomes for the Ballarat North precinct” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 5). The four nominated innovation items (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6):

Delivering a microgrid energy model.
Embedding carbon neutrality, 7-star energy targets and ESD within the PSP.
Neighbourhood waste management.
Biodiversity corridor protections.

Each of these has practical consequences for development feasibility in the Northern Growth Area:

Microgrid energy model. Requires site-wide electrical infrastructure architecture different from standard distributor-provided reticulation. Likely triggers coordination with AusNet/Powercor and may require Negotiated Connection Agreements. DCP implications: potential DCP-funded or developer-funded renewable generation and storage.
Carbon neutrality + 7-star energy targets + ESD in PSP. 7-star NatHERS is already required for new homes under the National Construction Code 2022 uplift; “within the PSP” implies a higher obligation potentially reaching 8-star or Passive House standards, plus precinct-level carbon accounting. For developers this adds marginal cost per lot (estimates for 8-star vs 7-star typically range $5,000-$ 15,000 per dwelling depending on climate zone and build form).
Neighbourhood waste management. Suggests precinct-level organics or materials-recovery infrastructure rather than kerbside-only. May require a waste precinct reservation within the PSP and DCP funding for capital works.
Biodiversity corridor protections. Cross-referenced with the Burrumbeet Creek corridor on the western boundary. Implies waterway setbacks (commonly 30–60 m from top of bank for Class 1 waterways), retention of native vegetation along the creek, and potentially a Native Vegetation Precinct Plan (NVPP) process akin to the ballarat-west-nvpp.

The Innovation Pathway functions as policy-level compensation for the constrained “expanded area” decision: it shifts the amendment from a purely quantitative land-supply intervention to a quality-of-outcome pilot. It also creates statewide policy risk/opportunity for Ballarat — the PSP is described by Council officers as “a Statewide replicable process for designing a proof of concept” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6). Whatever Ballarat negotiates will likely become the template used in subsequent regional-city PSPs.

3. Western and North-Western Growth Areas — unresolved since 2022

Western Growth Area (1,170 ha gross, ~896 ha NDA, ~13,440 dwellings)

The February 2022 officer report described the Western Growth Area as “a logical extension of the Ballarat West Precinct Structure Plan” with:

Flat topography and “largely consolidated land ownership patterns” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 55).
The Skipton Rail Trail and Finches Road forming a logical boundary (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 55).
Bells Road to the south as a logical conclusion and interface to Golden Plains Shire (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 57).
Proximity to the “Glenelg Highway Major Town Centre” supporting residential growth west of Kensington Creek (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 58).
A “future temporary pump station” to the north enabling land servicing (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 59).

The Western Growth Area is the largest of the three in dwelling capacity (13,440 dwellings = 54% of the combined C221ball yield) and in NDA (896 ha = 51% of combined NDA). Its loss from the original amendment has the largest single impact on Ballarat’s 20-year supply picture.

North-Western Growth Area (690 ha gross, ~500 ha NDA, ~5,000 dwellings)

The North-Western Growth Area was flagged as a “longer term growth option to accommodate future populations” — specifically framed for “an aspirational population of over 200,000” beyond the 2.5%/annum benchmark (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 61). It is west of the Skipton Rail Trail, currently zoned Comprehensive Development Zone. The February 2022 estimate assumed 15 dwellings/ha and 5,000 dwellings (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 62).

Several submissions during the 2020 consultation requested inclusion of the North-Western area in the Council boundaries (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 18, 60), and Council responded by including it as a potential future growth corridor. The Minister’s bifurcation decision removed both the Western and North-Western fronts from the initial rezoning round, on the basis that further sequencing analysis was required.

The IGAF — what the Minister required before Western/NW UGZ application

On 31 August 2022, the then Minister for Planning requested the VPA prepare a “High-Level Strategic Review” (HLSR) of Ballarat’s proposed greenfield land including the Western and North-Western growth areas and urban renewal areas (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 11). The VPA renamed this the Infrastructure Growth Alignment Framework (IGAF) in early 2023 (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 11).

The IGAF’s stated purpose was to provide a clear strategy for (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, paras 13, a–i; 24-september-2025-council-meeting-agenda-with-attachments.txt, para 13):

Future staging and sequencing of residential growth opportunities to accommodate projected 15-year population growth.
Clear directions on where growth should occur.
An evaluation of growth projections within the municipality.
A high-level look at land capability.
Service limitations.
Infrastructure costs.
Market trends.
An infrastructure review.
The need for any upgrades to accommodate population growth.

The IGAF’s trajectory has been opaque. The key milestones disclosed in the quarterly updates:

Date	IGAF milestone
31 Aug 2022	Ministerial request to VPA (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 11)
Jan 2023	Council officers wrote to new Minister seeking timeframes (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, paras 8–9)
Apr 2023	HLSR renamed to IGAF by VPA; output framed as “advice to the Minister for Planning” anticipated “before mid-2023” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, paras 11, 12)
Aug 2023	VPA “nearing completion of the IGAF” with advice to Minister “in September” (Source: 23-august-2023-council-meeting-agenda-with-attachments_part2.txt, para 11)
Dec 2023	Expected to be finalised “in early 2024” (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 14)
Mar 2024	”A brief on the IGAF to the Minister for Planning anticipated to be finalised in February by the VPA” (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 13)
Jun 2024	IGAF “has been submitted to the Minister for Planning for endorsement” (Source: 26-june-2024-council-meeting-agenda-with-attachments.txt, para 12)
Dec 2024	”The IGAF was provided to the Minister for Planning in February” with “initial release will be internal to Government and Council only” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 13)
Sep 2025	”It is unknown if or when the IGAF will be publicly released”; IGAF listed as priority project in the Victorian Government’s Housing Statement 2024–2025 (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, paras 14, 15)

The pattern is a three-year stretch of “about to be delivered” advice, repeatedly slipping, with the final disposition that the IGAF has been delivered to the Minister but is not publicly released. This is highly unusual for a document that was originally scoped as a public strategic review informing municipal planning decisions. Its retention as internal Government/Council advice means that:

The strategic rationale for holding Western/NW UGZ rezoning is not itself visible. Landowners, community and Council officers cannot test the IGAF’s logic through exhibition or Panel processes.
Council’s own subsequent Growth Areas Framework Plan was prepared without access to the final IGAF outputs. The 11 December 2024 update records the IGAF “will be reviewed following the release of the Plan for Victoria” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 13), suggesting the IGAF may be further overtaken by state policy.
Plan for Victoria (2024) is now the upstream controlling instrument. Plan for Victoria was released in 2024 as the state’s overarching land-use strategy. The VPA and DTP have signalled that the IGAF “may also be reviewed following the release of the Plan for Victoria” (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 13; 26-june-2024-council-meeting-agenda-with-attachments.txt, para 12). This creates a tiered dependency: the Western/NW UGZ rezoning depends on the IGAF, which depends on Plan for Victoria’s regional settings, which in turn depend on the Housing Statement 2024–2025 implementation program.

Growth Areas Framework Plan — Council’s parallel-track response

While the IGAF stalled, Council commissioned and delivered the Growth Areas Framework Plan covering the Western and North-Western Growth Areas (Source: growth-areas-framework-plan-western-and-north-western-growth-areas_august-2024.txt). The GAFP’s trajectory:

Draft endorsed for consultation by Council 8 May 2024 (Source: 26-june-2024-council-meeting-agenda-with-attachments.txt, para 13).
Public consultation closed 31 May 2024 (Source: 26-june-2024-council-meeting-agenda-with-attachments.txt, para 14).
Revised draft and final report to Council Planning Delegated Committee in August 2024.
Adopted by the Planning Delegated Committee on 14 August 2024 under resolution PDC21/24 (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, paras 15–16; 24-september-2025-council-meeting-agenda-with-attachments.txt, paras 4, 16).

Resolution PDC21/24 directed (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 16):

Adoption of the GAFP (revised August 2024).
Council officers to engage with state government authorities to progress implementation, including actions in the Implementation Plan.
Immediate commencement of future PSP work including early technical reports for the Western Growth Area, noting that simultaneous preparation of multiple PSPs can be supported through demonstrated need and strategic policy.
Establishment of a Housing and Growth Portfolio with at least two Councillor representatives, reporting six-monthly to Council on growth areas, PSP and housing analysis.
Noting that incorporating the GAFP into the Ballarat Planning Scheme would be the subject of a separate report and amendment.

This resolution re-opens the Western rezoning question. PDC21/24.3 directs early technical work for the Western PSP while the UGZ rezoning remains unauthorised. This is a significant strategic pivot: Council is preparing the evidentiary and design basis for a Western PSP in advance of a rezoning decision, which in turn positions a future Ministerial authorisation (a follow-on C221ball-like amendment, or a different identifier) to proceed quickly once the sequencing and servicing questions are resolved.

The September 2025 quarterly update confirms the Western pre-PSP work is in progress: “City of Ballarat officers have begun pre-PSP actions which will inform any future PSP, including undertaking a Cultural Values Assessment (Action 1) in line with resolution PDC21/24. The Wadawurrung Traditional Owners have been engaged to undertake this work, and landowners have been engaged to organise site visits” (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19).

See growth-areas-framework-plan for full analysis of the GAFP.

4. Housing Framework Plan — the forgotten half of C221ball

The February 2022 resolution had two limbs: (a) UGZ rezoning, and (b) “a policy amendment which introduces a new ‘Housing Framework Plan’ to support the next phases of planning” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.1(b)). The policy amendment component has received almost no attention in subsequent quarterly updates. It does not appear in the DTP Ministerial amendment (which rezoned the core but did not insert a Housing Framework Plan policy). It does not appear in the GAFP adoption resolution (PDC21/24 notes that a separate amendment would be required to incorporate the GAFP).

The practical status of the Housing Framework Plan policy amendment:

Unenacted. No evidence in the corpus that the policy has been inserted into the Ballarat Planning Scheme.
Superseded by the Growth Areas Framework Plan in substance. The GAFP appears to perform the spatial sequencing function that the Housing Framework Plan was intended to perform.
Dependent on the Ballarat Housing Strategy for full integration. The February 2022 Council resolution noted that “the Ballarat Housing Strategy should ultimately be the mechanism to determine the extent of future growth and infill development across Ballarat” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 72.4). The 11 December 2024 update records that “Council officers have sought authorisation from the Minister for Planning to prepare and exhibit a Planning Scheme Amendment together with the City of Ballarat Housing Strategy” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 17) — this is a distinct authorisation request, not C221ball.

The implication is that C221ball’s (b) limb has been abandoned in its original form. The replacement path is a combined amendment bundling the Housing Strategy, the GAFP and associated policy adjustments, authorisation for which was being sought as at late 2024 but had not been confirmed in the corpus as at September 2025.

5. PSP and DCP pathway for the Northern core — what C221ball enabled

C221ball’s successful core-area rezoning (via the 22 June 2023 Ministerial amendment) enabled the VPA to commence the ballarat-north-psp and its DCP. Key milestones to date (combining quarterly updates):

Date	PSP milestone	Source
Feb 2023	Ballarat North PSP selected as VPA Innovation Pathway pilot	26-april-2023-council-meeting-agenda-with-attachments_1.txt para 5
2023	Third-party funding agreements with landowners established	26-april-2023-council-meeting-agenda-with-attachments_1.txt para 16
2023–2024	Technical background reports commissioned: IWM, Historical Heritage, Land Capability, Adverse Amenity Impact (GHD May 2024), Cultural Heritage, Community Infrastructure	13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt para 6; 27-march-2024-council-meeting-agenda-with-attachments.txt para 6; vpa-ballarat-north-psp-adverse-amenity-impact-assessment-ghd.-may-2024.txt
Mar 2024	Co-design workshop expected “between March and June 2024 (pending the completion of technical background reports)“	27-march-2024-council-meeting-agenda-with-attachments.txt para 9
Jul 2024	Co-design workshop expected in July	26-june-2024-council-meeting-agenda-with-attachments.txt para 8
Dec 2024	Indicative draft PSP received by Council officers; “currently reviewing this with the intention to provide initial comment”	11-december-2024-council-meeting-agenda-with-attachments.txt para 10
19 Sep 2025	Formal exhibition of the Ballarat North PSP commenced (Minister for Planning announcement)	24-september-2025-council-meeting-agenda-with-attachments.txt para 8
Mid-2026	PSP gazettal expected	24-september-2025-council-meeting-agenda-with-attachments.txt para 9

The PSP is listed as a “priority project within the Victorian Government’s Housing Statement 2024–2025” (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 10), which confers elevated delivery priority and likely additional DTP/VPA resource allocation.

Sequencing dependency. Even with the core area now UGZ-zoned since June 2023, “no immediate urban development will occur in the Ballarat Northern Growth Area until the PSP and DCP have been prepared and incorporated into the Ballarat Planning Scheme” (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 9). The UGZ schedule effectively locks in a “no development until PSP” control, converting the C221ball land supply gain from a 2023 event into a mid-2026 event — approximately three years of latency between zone change and first-lot-possible.

Concurrent planning permits. One partial softening: “there are however opportunities to consider planning permit applications concurrent with the development of the PSP” (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 11). This reflects the UGZ’s ability to permit some applications (subject to Council discretion) before a PSP is in place, particularly for landowners with unambiguous approvals-pathways and infrastructure-ready parcels.

6. Amendment pathway and governance — what C221ball teaches

The C221ball journey illustrates a repeating pattern in regional Victorian greenfield rezoning:

(a) Section 8A applications for Council-led amendments in contested growth areas are increasingly redirected into Section 20(4) Ministerial amendments. Section 8A is the “standard” path — Council applies to the Minister for authorisation, then exhibits under Section 19, considers submissions, appoints a Panel if needed, adopts, and submits for Ministerial approval. Section 20(4) is the expedited path exempt from notice and submissions. The Minister’s September 2022 authorisation letter directed DELWP to prepare an amendment under Ministerial control (Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 4), effectively using the expedited path for the core area rezoning even though Council had proposed the standard Section 8A path. The 22 June 2022 update confirms this was explicitly contemplated: “the Minister is considering if his powers extend to enabling a Section 20(4) amendment to apply the Urban Growth Zone (UGZ) to the identified areas” (Source: 22-june-2022-council-meeting-agenda-with-attachments.txt, para 5).

For landowners, this pathway switch has two consequences:

No exhibition, no Panel. There is no public opportunity to object to or support the rezoning. Council’s 2020 consultation (58 submissions) was the only structured community input (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 16).
Ministerial discretion over boundary. The Minister can unilaterally change the Council-proposed boundary, as occurred here with the core/expanded split, without a Panel process to test the reasoning.

(b) VPA appointment as Planning Authority shifts downstream PSP governance. Traditionally, Council-led PSPs proceed with Council as Planning Authority, Council setting the brief for consultants, and Council adopting the PSP before submitting for Ministerial approval. With the VPA appointed (as occurred for the Northern PSP, Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 6), the VPA sets the brief, engages consultants (often funded through Third-Party Funding Agreements with landowners, Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 16), and the VPA Board signs off on the PSP before it goes to the Minister. Council’s role shifts to consultee, stakeholder reviewer and DCP co-negotiator.

(c) “High-Level Strategic Review” / IGAF-style interventions are becoming standard for regional-city greenfield rezoning. Before Plan for Victoria (2024), individual regional cities could proceed with UGZ rezoning based on their own strategic work. The IGAF’s interposition as a precondition for the Western/NW rezoning sets a precedent: state-level servicing and sequencing analysis is now an implied prerequisite to UGZ application in regional cities. This materially lengthens the rezoning pathway and reduces council autonomy over greenfield sequencing.

(d) Innovation Pathway selection creates policy co-benefit but delivery risk. The Innovation Pathway nomination (microgrid, 7-star, neighbourhood waste, biodiversity corridors) creates qualitative uplift but introduces delivery risk — each innovation must be converted from aspiration to scheme controls, funded through DCP or landowner contributions, and tested with referral authorities. Delays in innovation-pathway specification contribute to PSP timeline slippage.

7. Cross-jurisdictional and infrastructure dependencies

C221ball’s implementation intersects multiple state agencies and infrastructure authorities. The 23 February 2022 report’s Attachment C documents state agency consultation and confirms that “officers also engaged with key stakeholders within State Government” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 19), but the specific agencies and their positions are not tabulated in the corpus. Based on the functional requirements of a UGZ rezoning and subsequent PSP, the following agencies are implicated:

Agency	Role	Implication for C221ball land
Department of Transport and Planning (DTP)	Lead planning authority for Ministerial amendments; inheritor of DELWP planning functions post-2022	Approved the core area rezoning 22 June 2023; oversees VPA delegation on Northern PSP
Victorian Planning Authority (VPA)	Planning Authority for Northern PSP/DCP; Innovation Pathway host; IGAF preparer	Preparing PSP and DCP; delivered IGAF to Minister (not publicly released)
Central Highlands Water	Reticulated water and sewer supplier	Must extend servicing to Northern and (future) Western/NW growth areas. The 22 June 2022 update references a “future temporary pump station” enabling Western Growth Area servicing (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 59).
Powercor	Electricity distribution (Ballarat and western Victoria)	Must enable microgrid architecture under Innovation Pathway; standard UGZ servicing obligations
VicRoads / DTP Transport	Arterial road controls on Midland Highway, Western Highway, Remembrance Drive	Interface with Midland Highway (east boundary of Northern), Western Highway (south boundary of Northern). Likely intersection upgrades triggered at PSP stage.
Wadawurrung Traditional Owners Aboriginal Corporation	Registered Aboriginal Party for the land	Engaged for Cultural Values Assessment (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19); Cultural Heritage Management Plan likely required for the PSP area
Dja Dja Wurrung Aboriginal Clans Corporation	RAP for partly-overlapping area	Engagement noted in February 2022 report (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 21)
DEECA	Native vegetation, biodiversity, waterway planning	Responsible for native vegetation removal approvals; waterway setbacks along Burrumbeet Creek
CFA	Bushfire Management Overlay (BMO) referrals	Mount Rowan and the Burrumbeet Creek corridor may trigger BMO requirements
EPA	Adverse amenity separation distances (EPA Publication 1518; draft 1949)	Northern PSP requires compliance with EPA separation distance guidelines near industrial uses (Source: vpa-ballarat-north-psp-adverse-amenity-impact-assessment-ghd.-may-2024.txt)
Moorabool Shire / Golden Plains Shire / Hepburn Shire	Adjacent councils	Bells Road (south of Western Growth Area) is the interface with Golden Plains Shire (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 57). Cross-boundary infrastructure, drainage and settlement coordination implied.

Adjacent-council implications. The Bells Road boundary with Golden Plains Shire is particularly noteworthy: any development on the southern edge of the Western Growth Area will create interface issues with Golden Plains’ rural/settlement land. The Ballarat–Cargnham Road connection (part of the proposed Ballarat Western Link Road, referenced in the 23 February 2022 report’s consultation record, Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para ~9505) is the strategic transport link that would enable Western Growth Area development to integrate with the existing Ballarat West PSP area and with arterial connections south to Golden Plains.

8. Development feasibility implications

For landowners, developers, and Council, C221ball and its downstream outputs have concrete feasibility implications by growth front:

Northern Growth Area (core) — in force, PSP in exhibition

Feasibility status: Zone change in force since June 2023; PSP in exhibition from 19 September 2025; PSP gazettal targeted mid-2026; DCP levy rates yet to be published (as at September 2025).

Critical unknowns for core-area landowners:

Final DCP levy rate per hectare NDA (and per lot).
Final innovation pathway cost burden (microgrid, 7-star uplift, waste management, biodiversity corridors) and whether DCP-funded, landowner-funded, or cost-shared.
Mount Rowan landscape constraint — exact NDA deduction.
Burrumbeet Creek corridor setback distances — NVPP-equivalent process likely required.
Adverse amenity separation distances from existing industry (EPA 1518/1949 application, Source: vpa-ballarat-north-psp-adverse-amenity-impact-assessment-ghd.-may-2024.txt).

First-lot timing. With PSP gazettal mid-2026, first subdivision permits for core-area lots are likely late 2026 to early 2027, with first titles ~12–18 months thereafter (late 2027 to mid-2028) depending on lead-in infrastructure. This approximately corresponds to when Ballarat West supply is projected to be depleted (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 44) — tight sequencing with limited margin for further slippage.

Northern Growth Area (expanded) — held since 2022; VPA decided against inclusion December 2024

Feasibility status: Remains Farming Zone / Rural Living Zone. VPA has decided against inclusion in the PSP (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 8).

Critical unknowns:

Whether and when a fresh review of the expanded area will occur.
Whether Council will seek a Section 8A authorisation to pursue UGZ application independently.
Whether individual landowners can seek Section 173 agreements or spot-rezoning paths.

Land value implications. The expanded area has likely traded at a discount to the core since September 2022 (Ministerial authorisation letter) and at a further discount since December 2024 (VPA decided against inclusion). Without a statutory pathway back to UGZ status, englobo values will reflect Farming Zone / Rural Living Zone development potential only.

Western Growth Area — unauthorised, pre-PSP technical work in progress

Feasibility status: No rezoning authorisation. Early technical reports commissioned under PDC21/24.3 (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 16). Cultural Values Assessment with Wadawurrung TOs under way (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19).

Critical unknowns:

IGAF content and whether it supports or conditions Western rezoning.
Plan for Victoria regional implementation settings for Ballarat.
Ministerial appetite for UGZ application ahead of full IGAF implementation.
Whether Western PSP preparation will precede, accompany or follow a UGZ rezoning (the usual sequence is zone change first, but PDC21/24 contemplates parallel PSP work).

Timing. Based on current trajectory, a Western UGZ rezoning is unlikely before 2027–2028, with PSP gazettal 2030+ on an optimistic track. If Ballarat West depletes in 2025–2027 and Northern is in delivery from 2027–2028, the Western front is the first post-2030 supply response.

North-Western Growth Area — longer-term hold

Feasibility status: No rezoning authorisation. Recognised as longer-term supply dependent on an aspirational 200,000+ population trajectory (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 61).

Timing. Not expected to proceed ahead of Western. Realistic rezoning window 2030+.

9. Quantified municipal land supply implications

Consolidating the above into a supply ledger:

Horizon	Supply source	Approximate remaining lots	Cumulative years at 1,000 lots/year
2026	ballarat-west-psp residual	4,000–5,000 (after continuing burn since 2022 estimate of 6,000 at 2024/25)	4–5
2027–2032	Ballarat North core (after PSP gazettal mid-2026)	5,000–5,800 (post-constraint NDA × 15 dw/ha)	5–6
2030+	Western Growth Area (subject to rezoning)	~13,000 (if 1,170 ha / 896 ha NDA assumptions hold)	~13
2035+	North-Western Growth Area (subject to rezoning and IGAF)	~5,000	~5

Net finding. If the Western Growth Area does not rezone by 2028 and PSP-gazette by 2031, Ballarat faces a greenfield supply gap between ~2032 (Northern core exhaustion at 1,000 lots/year) and Western PSP first-lot delivery. The expanded area decision removed a buffer. This is the structural risk that Council’s PDC21/24.3 resolution (early Western PSP work) is intended to mitigate, and it is the core reason the IGAF and Plan for Victoria settings matter operationally.

10. Contested issues and submissions

Unlike Amendment C256ball and other major amendments with formal exhibition, C221ball has not been exhibited and has not received formal submissions under Section 19. The only structured public input in the corpus is from the November–December 2020 growth areas boundary consultation (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 14–19), which yielded 58 submissions and informed the Council boundary recommendations.

The principal contested issues emerging from the 2020 consultation and subsequent process (as far as discernible from the corpus):

Inclusion of the North-Western Growth Area. Several 2020 submissions requested inclusion of the NW area, which Council agreed to in its February 2022 boundary, but which the Minister subsequently deferred via the IGAF pathway (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 18, 60–64).
Core vs expanded area split. Council recommended a Northern Growth Area larger than the original Growth Investigation Area. The Minister disaggregated this. Expanded-area landowners have (on current corpus evidence) had no opportunity to test this decision through a Panel process.
Infill vs greenfield balance. Council’s Clause 21.02 settings aspire to a 50/50 infill/greenfield split, but actual delivery is approximately 30% infill / 70% greenfield (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 25, 41). The C221ball greenfield release tilts the balance further toward greenfield in the short-to-medium term, which may attract community submissions at the PSP exhibition stage.
Innovation Pathway cost burden. The cost of delivering microgrid, 7-star, neighbourhood waste and biodiversity corridor innovations has not been publicly quantified. At the PSP/DCP exhibition stage, expect submissions from landowners on DCP levy rates and from community on delivery confidence.
Heritage and landscape values. Mount Rowan is flagged as requiring detailed landscape assessment. Burrumbeet Creek corridor has biodiversity and possibly Cultural Heritage significance. Any homesteads or rural heritage places within the growth areas will require assessment — likely several heritage places will be identified through the PSP process.

11. Lifecycle summary — the four-year record

Date	Event	Source
16 Sep 2020	Council resolves to pursue UGZ application for Northern and Western Growth Investigation Areas	23-february-2022-council-meeting-agenda-with-attachments_part1.txt para 6
Nov–Dec 2020	Community consultation on growth area boundaries (mailout, MySay survey, information sessions); 58 submissions	23-february-2022-council-meeting-agenda-with-attachments_part1.txt paras 14–16
23 Feb 2022	R14/22 adopted — authorisation sought for C221ball (UGZ rezoning + Housing Framework Plan); Cr McIntosh calls for governance briefing	d-22-28671-23-february-2022-council-meeting.txt; 23-february-2022-council-meeting-agenda-with-attachments_part1.txt
13 Apr 2022	Request to VPA to be Planning Authority for Northern PSP	22-june-2022-council-meeting-agenda-with-attachments.txt para 7
22 Jun 2022	Council update: Minister considering Section 20(4) pathway; draft Section 19 documentation also prepared	22-june-2022-council-meeting-agenda-with-attachments.txt paras 5, 9
Jul 2022	City of Ballarat applies to VPA Innovation Pathway pilot	26-april-2023-council-meeting-agenda-with-attachments_1.txt para 4
31 Aug 2022	Former Minister requests VPA prepare HLSR (later renamed IGAF)	27-march-2024-council-meeting-agenda-with-attachments.txt para 11
6 Sep 2022	Minister for Planning authorises DELWP to prepare, adopt and approve amendment to rezone core area only of Northern Growth Area and make policy changes; VPA appointed PSP planning authority	14-december-2022-council-meeting-agenda-with-attachments.txt para 4
14 Dec 2022	Council notes progress; writes to new Minister seeking IGAF, rezoning and PSP timeframes	14-december-2022-council-meeting-agenda-with-attachments.txt paras 11.1–11.2
Feb 2023	VPA Board selects Ballarat North PSP as Innovation Pathway pilot	26-april-2023-council-meeting-agenda-with-attachments_1.txt para 5
Apr 2023	HLSR renamed IGAF; advice to Minister anticipated before mid-2023	26-april-2023-council-meeting-agenda-with-attachments_1.txt paras 11–12
22 Jun 2023	DTP approves amendment rezoning core area of BNGA to UGZ; PSP/DCP preparation by VPA confirmed	23-august-2023-council-meeting-agenda-with-attachments_part2.txt para 4
23 Aug 2023	Council notes core-area rezoning; expanded area remains under investigation	23-august-2023-council-meeting-agenda-with-attachments_part2.txt paras 4–8
Sep 2023	IGAF “nearing completion”, advice to Minister anticipated September	23-august-2023-council-meeting-agenda-with-attachments_part2.txt para 11
13 Dec 2023	Quarterly update — technical background reports (IWM, Historical Heritage, Land Capability) in preparation; co-design workshop expected March 2024	13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt paras 6, 9
Feb 2024	IGAF brief to Minister finalised (per VPA advice to Council)	27-march-2024-council-meeting-agenda-with-attachments.txt para 13
27 Mar 2024	Quarterly update — PSP co-design workshop expected March–June 2024	27-march-2024-council-meeting-agenda-with-attachments.txt paras 6–10
8 May 2024	Draft Growth Areas Framework Plan endorsed for consultation	26-june-2024-council-meeting-agenda-with-attachments.txt para 13
31 May 2024	Public consultation on draft GAFP closes	26-june-2024-council-meeting-agenda-with-attachments.txt para 14
26 Jun 2024	Quarterly update — IGAF “submitted to the Minister for Planning for endorsement”; PSP co-design workshop expected July	26-june-2024-council-meeting-agenda-with-attachments.txt paras 8, 12
14 Aug 2024	Planning Delegated Committee adopts Growth Areas Framework Plan (PDC21/24); directs early Western PSP work; establishes Housing and Growth Portfolio	11-december-2024-council-meeting-agenda-with-attachments.txt paras 15–16
Dec 2024	VPA position confirmed: expanded area will not be included in the PSP; indicative draft PSP received by Council	11-december-2024-council-meeting-agenda-with-attachments.txt paras 8, 10
19 Sep 2025	Minister for Planning announces formal exhibition of Ballarat North PSP commences	24-september-2025-council-meeting-agenda-with-attachments.txt para 8
24 Sep 2025	Quarterly update — IGAF status: “unknown if or when the IGAF will be publicly released”; Western/NW GAFP actions in progress, including Cultural Values Assessment with Wadawurrung TOs	24-september-2025-council-meeting-agenda-with-attachments.txt paras 14, 19
Mid-2026 (target)	Ballarat North PSP gazettal	24-september-2025-council-meeting-agenda-with-attachments.txt para 9

12. What C221ball teaches about regional greenfield rezoning under the current Victorian system

Several generalisable lessons from the C221ball journey, relevant to Council officers, landowners and policymakers:

(a) Council-proposed boundaries are not the controlling boundaries. Even with detailed strategic justification (Clause 21.02-4 alignment, PPN90 compliance, UDP methodology, 58 community submissions, 6-month documentation drafting), the Minister can impose a different boundary. The “core vs expanded” split reduced the Northern land supply by approximately 25% relative to Council’s proposal.

(b) Ministerial Section 20(4) pathways are faster but opacity-tolerant. Nine months from authorisation (Sep 2022) to gazettal (Jun 2023) is quick by Victorian standards — a standard Section 19/20 path with Panel would typically take 18–30 months. The speed comes at the cost of no exhibition and no Panel, which means no public testing of boundary decisions.

(c) Multi-front rezoning is unlikely to succeed as a single amendment. C221ball’s collapse into three separate tracks (Northern core via Ministerial amendment, Northern expanded via “further investigation”, Western/NW via IGAF + GAFP + pre-PSP) suggests that bundling greenfield rezoning across multiple growth fronts invites Ministerial disaggregation. Future councils may be better served by sequential single-front amendments with pre-agreed IGAF-equivalent analyses.

(d) Infrastructure analysis (IGAF) can become a de facto moratorium. Without a fixed timeline or publication commitment, the IGAF has functioned as a three-year-plus hold on Western/NW rezoning. This is a significant governance learning: state infrastructure reviews commissioned as preconditions to rezoning need statutory timeframes or else they can indefinitely defer downstream planning decisions.

(e) Plan for Victoria changed the strategic context mid-process. Plan for Victoria’s 2024 release introduces new settings for regional growth, which the VPA has signalled may cause the IGAF to be reviewed. Amendments running during state-policy transitions face compounding dependency risk.

(f) Innovation Pathways add policy depth but delivery complexity. The Innovation Pathway’s four pillars (microgrid, 7-star, waste, biodiversity) are genuine planning gains, but each adds a negotiation strand to the PSP/DCP with referral authorities and landowners. The PSP timeline from 2023 authorisation to 2026 gazettal reflects this complexity.

Current Status

As at 16 April 2026:

Northern Growth Area core: UGZ rezoned since 22 June 2023; PSP in formal exhibition since 19 September 2025; PSP gazettal targeted mid-2026; DCP preparation concurrent. Listed as priority project in Victorian Housing Statement 2024–2025.
Northern Growth Area expanded: VPA position confirmed (December 2024) as not for inclusion in the Northern PSP. Remains Farming Zone / Rural Living Zone. No active pathway to UGZ rezoning.
Housing Framework Plan policy: Not enacted in its originally-proposed form; superseded in substance by the Growth Areas Framework Plan (adopted 14 August 2024); separate amendment to incorporate the GAFP and Housing Strategy into the planning scheme has been sought from the Minister (11 December 2024) but not confirmed in the corpus.
Western Growth Area: UGZ rezoning unauthorised. Pre-PSP technical work in progress under PDC21/24.3. Cultural Values Assessment with Wadawurrung Traditional Owners engaged (September 2025).
North-Western Growth Area: UGZ rezoning unauthorised. Longer-term growth hold. No active pre-PSP work disclosed.
IGAF: Provided to Minister for Planning February 2024; not publicly released as at September 2025. Listed as priority project in Housing Statement 2024–2025. May be reviewed following Plan for Victoria.

Lifecycle classification: C221ball is a PARTIALLY RESOLVED amendment. Its northern objective has been delivered via a substitute Ministerial amendment (core area rezoning) but not via C221ball itself. Its expanded-area and western/NW objectives remain formally unresolved; in practice, the expanded area is not being pursued, and the western/NW fronts are now being pursued through a different amendment pathway yet to be authorised.

Dependencies

Blocks: Ballarat North PSP subdivision delivery (until gazetted, mid-2026 target); Ballarat North DCP collection (dependent on PSP gazettal); Western/NW PSP commencement (dependent on future UGZ rezoning pathway); Mt Rowan landscape controls (require PSP to define); Burrumbeet Creek corridor NVPP-equivalent controls (require PSP).
Blocked by: Ministerial decisions on expanded area (decided against inclusion Dec 2024); IGAF finalisation (delivered to Minister but not publicly released); Plan for Victoria regional settings; VPA-led Northern PSP exhibition outcomes; referral authority positions (Central Highlands Water, VicRoads/DTP Transport, CFA, EPA, DEECA); Cultural Heritage Management Plan finalisation; Third-Party Funding Agreements between VPA and landowners.
Informed by: ballarat-west-psp experience (density, DCP structure, subdivision burn rate); Ballarat Long Term Growth Options Investigation 2018 (Northern Growth Area identification); 2020 community consultation (boundary input); VPA Innovation Pathway selection (Feb 2023, four-pillar sustainability framework); VPA technical reports (IWM, Historical Heritage, Land Capability, Adverse Amenity [GHD May 2024], Cultural Values Assessment).
Implements: Clause 21.02-4 of the Ballarat Planning Scheme (compact-city greenfield direction); Ballarat Strategy 2040 (considered growth); DELWP/DTP Planning Practice Note 90 (15-year land supply obligation); Victorian Housing Statement 2024–2025 (Ballarat North PSP as priority project); R14/22 (Council resolution of 23 February 2022).
Conflicts with: Expanded-area landowner expectations (Council boundary vs Ministerial boundary); Council’s proposed 50/50 infill/greenfield split (actual delivery 30/70); Dowling Forest Racecourse / Equine Precinct interface (land use transition).

Cross-Jurisdictional Links

Golden Plains Shire: Bells Road boundary (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 57). Shared infrastructure coordination required (roads, drainage) if Western Growth Area proceeds. The proposed Ballarat Western Link Road connecting Western Highway, Remembrance Drive and Ballarat-Cargnham Road would traverse the interface and is flagged as a priority transport connection (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para ~9505).
Moorabool Shire: Adjacent to Ballarat’s north-eastern settlement boundary. While not directly within C221ball’s growth area boundaries, settlement growth patterns interact.
Hepburn Shire: Adjacent to the Northern Growth Area via Dowling Forest. The Equine Precinct interface and regional tourism/rural landscape values are cross-boundary issues.
Central Highlands Water: Shared water/sewer servicing authority. A temporary pump station flagged for Western Growth Area servicing (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 59). Sewer augmentation requirements likely to constrain Northern PSP staging.
Plan for Victoria (2024): State-wide overlay that may cause the IGAF to be re-examined (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 13). Regional growth settings now the upstream controlling instrument.
Housing Statement 2024–2025: Ballarat North PSP and IGAF both listed as priority projects (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, paras 10, 15). Confers delivery urgency and likely unlocks additional DTP/VPA resourcing.

_index — Ballarat planning overview.
_current — Current planning intelligence dashboard.
_timeline — Chronological event log.
_gaps — Missing documents and corpus gaps.
_index — Growth areas overview.
northern-growth-area — Ballarat North Growth Area deep-dive.
ballarat-north-psp — Ballarat North PSP analysis.
western-growth-area — Western Growth Area deep-dive.
nw-growth-area — North-Western Growth Area deep-dive.
growth-areas-framework-plan — GAFP analysis (adopted August 2024).
ballarat-west-psp — Existing growth area context.
ballarat-west-dcp — DCP precedent.
alfredton-west-psp — Adjacent/related PSP.
ballarat-west-nvpp — Native vegetation precedent.
growling-grass-frog-cmp — Biodiversity corridor precedent.
_index — Strategic planning framework.
water-sewer — Central Highlands Water servicing.
transport — Arterial road and link road coordination.
heritage — Mount Rowan and rural heritage.
bushfire — BMO implications.
c258 — Related Ministerial amendment (core area rezoning substitute).
c248 — Potentially related planning scheme amendment (GAFP incorporation pathway, if proceeded).

Gaps in This Analysis

The following documents are referenced in the corpus or are standard outputs for a process at this stage but are not held in the corpus as at 16 April 2026. These gaps materially limit the analysis:

Attachments E, F and G to the 23 February 2022 Council report. Referenced throughout (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, paras 18645–18647; d-22-28671-23-february-2022-council-meeting.txt, para 853) as the authoritative boundary maps. Their specific coordinates, areas and interfaces are not reproducible from the text record. Priority: IMPORTANT.
Attachment B Submissions Report (2020 consultation, 19 pages, 58 submissions). Would enable analysis of the substantive issues raised on boundaries. Priority: IMPORTANT.
Attachment C State Agency Consultation record. Would identify specific agency positions on each growth front. Priority: CRITICAL for Western/NW sequencing analysis.
Attachment H Site Analysis. Would contain topographic, ownership, constraint mapping for Western and Northern. Priority: IMPORTANT.
Minister for Planning authorisation letter, 6 September 2022. The instrument that bifurcated the amendment. Priority: CRITICAL.
DTP amendment approval / gazettal, 22 June 2023 (core area rezoning). The statutory instrument that delivered the UGZ for the core. Amendment identifier (likely a Ministerial amendment, possibly C258ball or a variant) is not clearly cited in the corpus. Priority: CRITICAL.
Infrastructure Growth Alignment Framework (IGAF). Delivered to Minister February 2024; not publicly released. Without it, the Western/NW rezoning pathway cannot be fully analysed. Priority: CRITICAL.
VPA Innovation Pathway Implementation Plan. Referenced (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 7) but not in corpus. Priority: IMPORTANT.
Draft Ballarat North PSP (indicative draft received by Council December 2024). Not in corpus until exhibition commenced. Exhibition opened 19 September 2025. Priority: CRITICAL.
Ballarat North DCP. Co-prepared with PSP. Levy rates and infrastructure items not in corpus. Priority: CRITICAL.
VPA technical background reports — full suite: IWM, Historical Heritage, Land Capability, Community Infrastructure, Transport, Cultural Heritage, Cultural Values Assessment. Some (e.g., GHD Adverse Amenity, May 2024) are in corpus; most are not. Priority: CRITICAL.
Ballarat Long Term Growth Options Investigation (2018). Referenced as the foundational document that recommended Ballarat North. Priority: IMPORTANT.
Housing and Growth Portfolio six-monthly reports (post-Dec 2024). Established under PDC21/24.4; would provide post-GAFP implementation intelligence. Priority: IMPORTANT.
Plan for Victoria (2024) regional settings for Ballarat. State strategic context. Priority: CRITICAL.
Cultural Heritage Management Plan (Wadawurrung) for Northern Growth Area. Required for PSP gazettal. Priority: IMPORTANT.

See /Users/jamesdibble/projects/planning-harvester/data/gaps-c221-growth-area-ugz.txt for the gap-filling action list.

Extended Analysis — Technical Dimensions

The following extended sections address each technical dimension of the C221ball rezoning package at the level of specificity the schema requires. Because C221ball itself was not exhibited — and the bulk of the technical work was subsumed into the VPA-led Northern PSP/DCP process — these analyses draw primarily on the February 2022 Council report, the 2024 GHD Adverse Amenity Impact Assessment, the GAFP (August 2024), and the trail of quarterly updates. Where evidence is indirect, it is flagged as an inference.

13. Drainage and integrated water management implications

The February 2022 Council report identifies drainage and interface conditions defined by Burrumbeet Creek as a key constraint on the Northern Growth Area (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 52). The subsequent VPA technical program commissioned an Integrated Water Management (IWM) assessment to inform the Ballarat North PSP (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 6). The IWM assessment is not in the corpus at the level of hectare-by-hectare retarding basin detail, but the broad structure of what it will contain is predictable from comparable Victorian regional greenfield PSPs:

(a) Burrumbeet Creek corridor — the binding western constraint. Burrumbeet Creek forms the western boundary of the Northern Growth Area and (according to the February 2022 report) is a “bounded” constraint rather than an alignment feature within the growth area (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 49). Typical Class 1 waterway corridor setbacks in Victorian PSPs are 30–60 metres from top of bank, with additional flood fringe reservations where the 1-in-100 year flood extent exceeds the setback. For a waterway 3–5 km in length along the growth area boundary, this implies a corridor reservation of approximately:

30 m setback × 4 km = 12 ha
60 m setback × 4 km = 24 ha
Flood fringe (assuming 40 m average width) × 4 km = 16 ha

Combined waterway corridor and flood fringe reservation is likely in the range 20–35 ha. At 15 dw/ha this displaces 300–525 lots that would otherwise have been counted in the gross developable area.

(b) Retarding basins and wetlands. Victorian PSPs commonly include 4–8 stormwater retarding basins distributed across the precinct at approximately 1 basin per 80–150 ha of catchment, sized at 2–6 ha each. For a 376 ha NDA Northern Growth Area, expect 3–5 basins with combined land take of 10–20 ha. The exact locations will depend on topography and catchment delineation, but basins typically occupy the lowest points on the catchment grid — often the parcels that would otherwise have the highest lot yield due to flat, developable topography.

(c) Treatment trains and WSUD. Water Sensitive Urban Design elements (bio-retention swales, vegetated trafficable pavements, rain gardens at lot and street level) consume 3–5% of the road reserve width. On a typical 18 m collector road cross-section, this is 54–90 cm of additional permeability treatment — not a major land take but a pavement cost premium.

(d) Reticulated water and sewer — Central Highlands Water. The Northern Growth Area requires reticulated water supply and sewer collection from Central Highlands Water. The February 2022 report notes a “future temporary pump station” flagged for the Western Growth Area (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 59); equivalent upstream infrastructure for the Northern Growth Area is required but not specified in the corpus. Typical Central Highlands Water augmentation lead times are 2–4 years. If a Ballarat North sewer augmentation is not in CHW’s 2025–2028 capital works program, PSP staging in certain sub-precincts could be delayed.

(e) Innovation Pathway cross-over. One of the four innovation pillars is “neighbourhood waste management” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6), which is typically considered separately from drainage but in practice shares infrastructure land take — if a precinct-level organics or resource recovery facility is sited within the PSP, it occupies land that would otherwise be developable.

(f) Burrumbeet Creek cultural heritage sensitivity. Waterway corridors are commonly Cultural Heritage Sensitive Areas under the Aboriginal Heritage Regulations 2018. Any ground disturbance within 200 m of the creek is likely to trigger Cultural Heritage Management Plan requirements, with Wadawurrung Traditional Owners as the Registered Aboriginal Party. The GAFP records that Wadawurrung have been engaged for Cultural Values Assessment work on the Western Growth Area (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19); equivalent CHMP work will be required for the Northern PSP.

Net drainage/IWM implication for the Northern Growth Area. Combined waterway corridor, retarding basins, WSUD treatment trains, and cultural heritage sensitivities likely reduce the Council-estimated 376 ha NDA by a further 25–40 ha, or approximately 7–11%. This corresponds to 375–600 fewer lots at 15 dw/ha than the headline figure implies. DCP funding for drainage infrastructure is a standard inclusion in Victorian greenfield DCPs, so landowners can expect a per-hectare NDA levy contribution to drainage capital works rather than bearing full land-take costs out of development margin.

14. Transport dependencies and intersection upgrades

The Northern Growth Area is bounded by Western Highway (south) and Midland Highway (east), both arterial roads under VicRoads/DTP Transport management. The Burrumbeet Creek corridor defines the western boundary, meaning western access depends on limited bridge crossings. The Dowling Forest Racecourse and Equine Precinct to the north create a non-development interface.

(a) Midland Highway intersection upgrades. The Northern Growth Area will access the existing Ballarat urban area primarily via Midland Highway. Every 500–800 lots of development typically generates traffic movements requiring a new or upgraded signalised intersection. At the 6,190-lot indicative yield, expect 8–12 new or upgraded intersections on Midland Highway and connector roads. Typical cost per signalised intersection upgrade in regional Victoria is $1.5-4M depending on turn-lane complexity; combined intersection cost could range$ 15–40M. Without the Jacobs or equivalent Transport Assessment in the corpus, this is an order-of-magnitude estimate.

(b) Bridge over Burrumbeet Creek. If western connectivity to Miners Rest is to be achieved (the February 2022 report noted “close synergies to the Miners Rest township to its immediate west”, Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 50), at least one new bridge over Burrumbeet Creek is likely required. A regional arterial bridge in Victorian conditions typically costs $10–25M depending on span length and flood immunity. This is a DCP candidate item but may also require a joint funding agreement with DTP Transport.

(c) Western Highway interface. The Western Highway forms the southern boundary of the Northern Growth Area and also the northern boundary of the Western Growth Area. Its treatment is constrained by:

Speed limit and road-type controls (typically 80–100 km/h outside urban areas).
Limited access point density under Austroads design standards.
Potential for heavy-vehicle conflict with residential traffic.
Future potential for upgrading as part of the Ballarat Western Link Road corridor.

For the Western Growth Area specifically, the Ballarat Western Link Road is flagged as a priority transport connection connecting Western Highway, Remembrance Drive and Ballarat-Cargnham Road (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, ~para 9505). This is infrastructure that Council has been advocating for at state level; its delivery would materially reshape access to both the Western and North-Western growth areas and is a cross-boundary coordination issue with Golden Plains Shire.

(d) Ballarat airport interactions. The 11 December 2024 report records that the Ballarat Airport Runway Project is extending Runway 18/36 from 1,245 m to 1,800 m, with Airport Road discontinuance and renaming (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, paras 2–12). The airport is north-east of the CBD and not directly within the Northern Growth Area, but any Obstacle Limitation Surfaces (OLS) or Public Safety Areas (PSAs) associated with the runway extension may affect building heights or land use in the northern extremity of the growth area, particularly near the Equine Precinct interface. This is a PSP-stage detail that will be tested at exhibition.

(e) Public transport. Current PTV services to the northern fringes of Ballarat are limited. The GAFP’s implementation actions likely include bus route extension negotiations, but timing depends on PTV network planning cycles (typically 3–5 year revision windows).

(f) Freight conflicts. Midland Highway carries regional freight including rural produce from the Wimmera-Mallee. Heavy-vehicle routes through or adjacent to the growth area will require design treatments (segregated bus corridors, grade-separated cycling paths) that increase road reserve widths.

Net transport implication. Transport infrastructure is likely to be the largest single DCP line item. Without the Jacobs or VPA Transport Assessment in the corpus, dollar specifics cannot be stated, but the combined intersection, bridge, Western Link Road contribution and arterial interface costs for a fully-delivered three-growth-front program could plausibly reach $150-300M over 20 years. A single growth front (Northern core) is likely in the range$ 30–80M.

15. Heritage, landscape and rural character constraints

The February 2022 report identifies Mount Rowan as “a key feature of the Northern Growth Area” that will “require a detailed landscape assessment as part of the future structure planning process to ensure its ongoing protection as a significant natural feature protected from development” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 51). This is a substantive constraint with specific implications:

(a) Landscape significance. Mount Rowan is a volcanic cone visible across north-western Ballarat. Its visual significance is effectively a landscape overlay — either through a Significant Landscape Overlay (SLO) or through PSP design controls on height, setback, and vegetation retention. The February 2022 report notes Mt Rowan “creates separation to the rural living areas to the north and signals the northern entry into Ballarat more broadly” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 51). Protecting this view function likely requires:

A “no-development zone” on the upper slopes and summit.
Height restrictions on adjacent parcels (potentially 2-storey maximum within 500 m of the feature).
Vegetation retention on the flanks.
Road alignment controls to preserve key sight lines.

(b) Historical heritage. The VPA commissioned an Historical Heritage Assessment (Source: 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 6), not in the corpus. For a 722 ha growth area with rural farming history back to the 1850s gold rush era, expect identification of:

3–8 homesteads of local or state significance.
10–25 subsidiary rural structures (barns, shearing sheds, stables).
Mining relics (shafts, mullock heaps, water races) — Ballarat’s gold mining history extended into surrounding rural land.
Dry-stone walls and rural landscape features.

Each identified heritage place typically triggers either a Heritage Overlay (HO) inclusion in a separate amendment, or curtilage protections in the PSP. The c240 amendment demonstrates Council’s recent pattern of progressing heritage inclusions as separate amendments — it would be reasonable to expect a “C221-associated” heritage amendment following the PSP.

(c) Equine Precinct and Dowling Forest Racecourse. The Dowling Forest Racecourse is a regionally significant racing facility. The Equine Precinct around it includes training facilities and stables. Residential development adjacent to equine uses creates interface issues: dust, noise, early-morning training activity, manure management, large-animal safety. Typical PSP treatment is a 200–400 m transition buffer with compatible lower-intensity uses (rural living, open space, education). This buffer likely removes another 30–50 ha from the northern edge NDA.

(d) Rural heritage and cultural landscape. Beyond the homesteads themselves, the broader rural landscape of north-west Ballarat (basalt plains, mature River Red Gums, dry-stone walls, hedgerows) has cultural significance that may warrant retention. The Innovation Pathway’s “biodiversity corridor protections” pillar (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6) will likely integrate with cultural landscape retention through combined corridor reservations.

Net heritage/landscape implication. Combined Mount Rowan no-development area, historical heritage curtilages, Equine Precinct buffer, and cultural landscape retention likely reduce the 376 ha NDA by a further 25–50 ha (7–13%). The Ministerial decision not to include the expanded area may partly reflect that heritage and landscape constraints compound beyond the core area.

16. Bushfire management implications

Mount Rowan and the Burrumbeet Creek corridor — both vegetated features with topographic complexity — raise bushfire risk concerns. Under the Bushfire Management Overlay (BMO) and Country Fire Authority (CFA) design obligations:

(a) BMO trigger. The BMO applies where bushfire risk is moderate-to-high, based on fuel loads, slope, and aspect. The Northern Growth Area’s northern and western fringes are plausibly within BMO triggers. BMO application requires:

Bushfire Attack Level (BAL) assessment for each lot.
Defendable space around habitable buildings (typically 19–29 m radius).
Vegetation management plans.
Access and egress standards (minimum 2 exit routes for estates over 10 dwellings).

(b) PSP design implications. BMO-affected land typically requires lower density (12–15 dw/ha rather than 15–20 dw/ha) to accommodate defendable space between buildings and vegetation. If 10–15% of the Northern Growth Area is BMO-affected, this reduces lot yield on those parcels by approximately 20–25% vs unaffected parcels.

(c) CFA referral. The PSP will be a referral document to the CFA under Clause 66. CFA submissions are likely to focus on:

Mount Rowan vegetation management.
Burrumbeet Creek riparian vegetation fuel loads.
Water supply for firefighting (hydrant density and flow requirements).
Emergency access points.

(d) Western Growth Area lower risk. The Western Growth Area is described as having “flat topography” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 55) with less vegetation, implying lower bushfire risk. BMO is less likely to be triggered at scale, though localised areas near rural residential interfaces may require treatment.

17. Economic and retail feasibility

The GAFP preparation included commissioning an “economic feasibility and retail analysis” as part of the background technical work (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 14; 13-december-2023-council-meeting-agenda-with-attachments-reduced_part1.txt, para 17). The specific findings are not in the corpus at the detailed numerical level, but the framing questions are:

(a) Retail catchment sizing. For the Northern Growth Area at full build-out (6,190 dwellings × 2.4 persons/dw = ~14,900 persons at current household size), retail demand is approximately:

1 local town centre (5,000–10,000 m² GLA) serving the precinct.
2–3 neighbourhood activity centres (1,000–3,000 m² GLA) at walking-distance spacing.
Possibly 1 convenience centre per 1,000–1,500 dwellings.

The dominant existing retail centre — Miners Rest — is west of Burrumbeet Creek and may not draw strongly from the growth area if creek crossings are limited. The nearest major centre (Wendouree, Stockland) is south of Western Highway at approximately 5–8 km travel distance. A new local town centre within the Northern Growth Area is therefore likely to be part of the PSP.

(b) Employment land. Is the Northern Growth Area purely residential, or does it include an employment component? Recent Victorian greenfield PSPs typically include 5–15% employment land (commercial + industrial) to meet the VPP’s jobs-in-corridor objectives. If the Northern PSP includes 30–60 ha of employment land, the residential yield is reduced accordingly.

(c) Affordable housing. Recent Victorian PSPs have been negotiating voluntary or mandatory affordable housing targets in the range 5–15%. The Victorian Housing Statement 2024–2025 (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 10) includes affordable-housing delivery targets that the Northern PSP (as a priority project) is likely to implement at the higher end of this range.

(d) Long-run demand risk. Council’s 2.5% growth assumption predicated the amendment. The ViF benchmark of 1.7% growth (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, Table 1) would yield approximately 46,529 additional persons by 2040/41 rather than 72,611 — a 36% reduction in forecast demand. If the lower growth rate eventuates, the Western and North-Western fronts may not be required until 2045+, not 2035+.

18. Native vegetation and biodiversity

The Innovation Pathway’s fourth pillar — “biodiversity corridor protections” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6) — positions biodiversity as a structural design input rather than an afterthought. Practical implications:

(a) Native Vegetation Precinct Plan (NVPP). Comparable Victorian greenfield PSPs (including Ballarat West, see ballarat-west-nvpp) are accompanied by an NVPP that identifies remnant native vegetation, agrees offset requirements, and schedules clearances. For the Northern Growth Area, expect:

5–20 hectares of remnant native vegetation (Yellow Box / Grey Box Woodland fragments, scattered River Red Gum paddock trees).
Offset requirements under the Native Vegetation Regulations 2017 at ratios from 0.5:1 to 3:1 depending on condition class.
Offset costs in the range $30,000-$ 100,000 per hectare cleared.

(b) Growling Grass Frog and other listed species. The growling-grass-frog-cmp for Ballarat West provides precedent. Burrumbeet Creek may harbour Growling Grass Frog (Litoria raniformis) populations. If so, the Northern PSP requires a Conservation Management Plan (CMP) with connectivity corridors, breeding habitat retention, and mitigation measures. CMP land take is typically 5–15 ha.

(c) Other listed fauna and flora. The Ballarat region hosts several FFG-listed species including Matted Flax-lily (Dianella amoena) and Striped Legless Lizard (Delma impar). Survey work is required to confirm presence, and where found, population protection adds corridor reservations.

(d) Burrumbeet Creek as regional biodiversity asset. Burrumbeet Creek is part of the regional hydrology and biodiversity network. Its protection under the PSP links to DEECA’s regional waterway planning and potentially to the North Central CMA or Corangamite CMA (jurisdiction to be confirmed).

Net biodiversity implication. Native vegetation, offsets, CMP corridors and regional biodiversity connectivity likely consume a further 10–20 ha of the 376 ha NDA, with offset costs of $500,000-$ 2,000,000 that must be absorbed by landowners or the DCP.

19. Utility servicing — electricity, gas, telecommunications

(a) Electricity. The Northern Growth Area sits within the Powercor distribution network. Servicing a 6,190-dwelling precinct typically requires:

Extension of 22 kV or 66 kV feeders from the nearest zone substation.
At the growth rate implied, a new zone substation may be required at approximately 2,500–4,000 lots. Typical new zone substation cost: $15–30M with 3–5 year lead time.
The Innovation Pathway microgrid pillar introduces a departure from standard Powercor reticulation: on-site generation (solar + battery), potentially a community energy retailer arrangement, and site-wide demand management.

(b) Gas. Reticulated gas is typically extended through greenfield Victorian estates, though Plan for Victoria and state electrification policy are shifting this. For a PSP gazetted mid-2026, the default is likely all-electric new-build with no reticulated gas — aligning with the 7-star / carbon neutral innovation pillar.

(c) Telecommunications. NBN Co or equivalent fibre rollout is a standard greenfield developer obligation.

20. DCP levy rate estimation (per hectare NDA and per lot)

Without the Ballarat North DCP in the corpus, specific levy rates cannot be quoted. However, benchmarking against comparable Victorian regional and metropolitan greenfield DCPs gives an indicative range:

DCP precedent	Typical $/ha NDA	Typical $/lot (at 15 dw/ha)
Ballarat West DCP (current)	~ $100,000-$ 200,000	~ $6,700-$ 13,300
Melbourne growth area DCPs (post-2018)	~ $200,000-$ 400,000	~ $13,300-$ 26,700
Regional city DCPs with innovation uplift	~ $150,000-$ 300,000	~ $10,000-$ 20,000

If the Ballarat North DCP lands near the mid-point of the regional-innovation benchmark (~ $225,000/ha NDA), the total DCP revenue from the 376 ha NDA core area is approximately$ 85M. This would fund:

40–50% of transport infrastructure needs (balance from state contributions and general rates).
Most of the drainage capital works.
Community facility fit-outs.
Open space land acquisition (typically via equalisation mechanism rather than direct purchase).

Per-lot impact. At ~ $15,000/lot, the DCP is approximately 3-4% of a typical regional greenfield lot price (recent Ballarat lot prices$ 350,000–$450,000). This is within normal market absorption tolerance.

Innovation pathway premium. The four innovation pillars may add a 10–30% premium to the baseline DCP or equivalent landowner contributions, pushing per-lot costs to $18,000-$ 22,000. Whether this erodes development feasibility depends on the lot premium that the innovation outcomes command in the market.

21. Counterfactual — what if C221ball had proceeded as Council proposed?

A useful analytical exercise: what would Ballarat’s planning landscape look like if the Minister had authorised C221ball in its original Section 8A form, rather than bifurcating it?

(a) Timeline. A standard Section 19 exhibition + Panel + Section 29 adoption + Section 35 approval cycle would have taken approximately 18–30 months from authorisation. If authorised mid-2022, exhibition late 2022, Panel mid-2023, adoption late 2023, gazettal early-to-mid 2024. This is approximately 6–12 months slower than the actual Ministerial pathway for the core, but — critically — would have delivered all three growth fronts simultaneously, 2–3 years ahead of the actual west/NW rezoning trajectory.

(b) Panel. A Panel on C221ball as proposed would likely have addressed:

Expanded area inclusion justification.
Western Growth Area boundary (Bells Road, Finches Road, Skipton Rail Trail alignment).
North-Western Growth Area status (long-term growth option vs immediate rezoning).
Housing Framework Plan policy wording.
50/50 infill/greenfield aspiration vs 30/70 actual delivery.

Panel directions on these issues would have set statutory precedents visible in the public record, rather than the current opaque Ministerial decisions.

(c) Sequential PSP commencement. With UGZ in place across all three growth fronts, PSP commencement could have been sequenced by Council on strategic grounds. Current trajectory has Northern PSP completing ~2026, Western commencing pre-PSP ~2025 without rezoning, and NW on indefinite hold — a less efficient pipeline than a sequenced three-front program would have enabled.

(d) Supply cliff. In the counterfactual, municipal greenfield supply would have been at 20+ years by mid-2024 (Ballarat West residual + UGZ land across three fronts). In reality, municipal greenfield supply is likely to drop to 6–8 years in 2026–2027 (Northern core only, plus Ballarat West residual), tightening through 2030 if Western rezoning is further delayed.

(e) Why the Minister rejected the Council path. The available evidence suggests the Ministerial rationale for bifurcation was:

The expanded area had less strategic justification than the core.
The Western and NW fronts required infrastructure sequencing analysis (IGAF) that Council had not yet produced.
A Section 20(4) expedited pathway for the core was faster than allowing C221ball to proceed through the standard path.
The VPA was the preferred vehicle for PSP preparation in priority growth areas.

This is a strategic posture rather than a failure of Council’s work. But it demonstrates that in the current Ministerial/VPA-dominated regional greenfield planning system, Council-proposed multi-front amendments face structural headwinds.

22. Comparative context — other regional Victorian cities

Ballarat’s growth-front rezoning challenge is not unique. Comparable regional cities pursuing UGZ rezoning in recent years include:

(a) Greater Geelong. The Northern and Western Geelong Growth Areas (NWGGA) have been subject to similar VPA-led processes with an overarching Framework Plan. Geelong’s process has been longer than Ballarat’s and includes multiple Panel hearings.

(b) Greater Bendigo. Bendigo has pursued growth-front rezonings through Council-led Section 19 amendments with Panel hearings, rather than Ministerial Section 20(4). The difference reflects political and administrative preferences.

(c) Mitchell Shire / Whittlesea / Melton. Melbourne fringe councils operate primarily through VPA-led PSPs; their rezoning is typically achieved through state-led amendments (C-series) attached to specific PSPs.

The Ballarat pathway — Council-proposed multi-front UGZ + Ministerial-led bifurcation + VPA Innovation Pathway pilot — is an unusual hybrid. It is simultaneously more experimental (Innovation Pathway) and more restricted (expanded area decision) than most comparable regional trajectories.

23. Strategic value of the Innovation Pathway selection

The VPA Board’s selection of Ballarat North as the Innovation Pathway pilot in February 2023 (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 5) is a significant policy positioning. Its implications extend beyond the Ballarat North PSP itself:

(a) Statewide replicable process. Council officers describe the pilot as creating “a Statewide replicable process for designing a proof of concept” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6). This means whatever planning controls, DCP structures, and design outcomes are negotiated for Ballarat North will become templates used in subsequent PSPs statewide.

(b) Ballarat as policy exporter. Ballarat has historically been a policy taker in state planning matters. Innovation Pathway selection positions it as a policy exporter — particularly valuable for a regional city seeking to influence state policy settings.

(c) Risk of overreach. Innovation commitments that prove undeliverable at scale (microgrid cost overruns, 7-star compliance failures, precinct-level waste management impracticalities) would damage the Ballarat North PSP’s market reception and the Pathway’s broader credibility. Close management of the Innovation Pathway deliverables is therefore a critical Council and VPA risk.

(d) Funding dependency. Innovations typically require some grant funding, corporate partnership, or premium-price lot sales to justify additional capital costs. The corpus does not disclose specific funding arrangements for the four pillars. A funding shortfall on any pillar would force either de-scoping of innovation commitments or delays to PSP gazettal.

24. Financial implications for Council

C221ball’s direct financial implications for Council were initially framed as nil (Source: 22-june-2022-council-meeting-agenda-with-attachments.txt, para 7). This framing has held through subsequent quarterly updates (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 5). However, the broader growth-area program carries material financial dimensions:

(a) DCP revenue accrual. Once the Ballarat North DCP is gazetted and collection begins, Council will collect DCP levies on behalf of the infrastructure projects identified. DCP funds are held in trust accounts separate from general rates. Collection rates of $85M over 20 years correspond to approximately$ 4.3M/year in DCP inflow, peaking in high-subdivision years.

(b) Non-DCP infrastructure co-contributions. Council is typically required to co-fund infrastructure that the DCP does not fully cover — community centres, sporting fields, roads beyond DCP scope. The 11 December 2024 update notes “Council’s proposal to undertake a staged roll-out of the growth areas will stage Council’s financial responsibilities associated with the construction of community and other infrastructure projects” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 7).

(c) Rates base growth. Fully-built Northern Growth Area at 6,190 dwellings adds approximately $10–15M/year in residential rates revenue to Council’s base, offsetting service delivery costs.

(d) Ballarat West DCP review and amendment. The 24 September 2025 Financial Plan records that “At the time of preparing the Financial Plan Council were undertaking a review of the PSP and DCP which will propose an amendment to the relevant planning scheme” for the Ballarat West DCP (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 12970s). Lessons from the Ballarat West DCP review will likely inform the Ballarat North DCP scope.

(e) Borrowing implications. Council’s Financial Plan 2025–2035 anticipates $142.4M in net new borrowings to support$ 1.03 billion of capital works over ten years (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para ~13049). Growth area infrastructure co-contributions are embedded in this capital program; the borrowing strategy depends on timely DCP inflows to service debt.

25. Community engagement and submission-process implications

Because C221ball has not been exhibited, no formal submission process has tested community support. The 2020 Growth Investigation Area boundary consultation (58 submissions) is the sole structured public input. Subsequent engagement has been through:

(a) Quarterly council updates. The R14/22.7 requirement for quarterly reporting has generated at least 15 Council reports between June 2022 and September 2025. These are public reports but function as officer updates rather than community engagement.

(b) GAFP consultation (May 2024). Public consultation on the draft GAFP closed 31 May 2024 (Source: 26-june-2024-council-meeting-agenda-with-attachments.txt, para 14). Submissions were reviewed and the revised GAFP was adopted 14 August 2024. The volume and substance of submissions is not in the corpus.

(c) Ballarat North PSP exhibition (from 19 September 2025). The formal exhibition of the Northern PSP is now the principal statutory engagement vehicle for the public on the substantive spatial and infrastructure outcomes. Submissions received during this exhibition will be considered by the VPA as Planning Authority before the PSP is submitted to the Minister for approval.

(d) Innovation Pathway engagement. Specific engagement on the four innovation pillars has been primarily through the VPA-led technical process rather than public consultation. This creates a risk that community expectations on what “innovation” means do not match what is ultimately delivered.

(e) Wadawurrung Cultural Values Assessment (Western, 2025). The Cultural Values Assessment under PDC21/24 Action 1 is a formal engagement with Wadawurrung TOs on the Western Growth Area (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19). This is distinct from the CHMP process for the Northern Growth Area.

26. Governance timeline — who decided what, when

A summary of governance decision-points across the C221ball journey:

Decision	Decider	Date	Vehicle
Long-Term Growth Options Investigation	Council officers	2018	Officer report
Initial UGZ application resolution	Council	16 Sep 2020	Council resolution
Community consultation framing	Council	Nov–Dec 2020	Mailout + MySay survey + info sessions
Recommended boundaries (N, W, NW)	Council	23 Feb 2022	R14/22
Amendment identifier C221ball	Council (via officer drafting)	23 Feb 2022	Amendment documentation
Section 20(4) vs Section 19 pathway question	Minister	Aug–Sep 2022	Ministerial discretion under P&E Act
Authorisation to DELWP to rezone core area + policy changes	Minister	6 Sep 2022	Authorisation letter
VPA appointment as Planning Authority for Northern PSP	Minister	Sep 2022	Statutory appointment
HLSR/IGAF commissioning	Minister	31 Aug 2022	Ministerial request to VPA
Innovation Pathway pilot selection	VPA Board	Feb 2023	VPA Board resolution
Core area rezoning gazettal	Minister (via DTP)	22 Jun 2023	Ministerial amendment
IGAF renaming and scoping	VPA	Apr 2023	VPA internal
Expanded area not-for-inclusion decision	VPA (confirmed to Council)	Dec 2024	VPA advice
Growth Areas Framework Plan adoption	Council Planning Delegated Committee	14 Aug 2024	PDC21/24
Western Growth Area pre-PSP work commencement	Council	Post-Aug 2024	PDC21/24 Action 1
Cultural Values Assessment commencement	Council + Wadawurrung	Pre-Sep 2025	Engagement agreement
Northern PSP exhibition commencement	Minister	19 Sep 2025	Ministerial announcement
Northern PSP gazettal (target)	Minister	Mid-2026	Ministerial approval
IGAF public release	Minister	Unknown	Ministerial discretion
Western UGZ rezoning	Minister (future)	2027–2029 (indicative)	Future Section 8A or 20(4) pathway
NW UGZ rezoning	Minister (future)	2030+ (indicative)	Future amendment pathway

The governance distribution reveals the core structural feature: every binding decision from September 2022 onward is made by the Minister for Planning, the VPA Board, or the VPA Acting as Planning Authority. Council’s role has been advisory, preparatory, and reactive. Council’s only binding decisions in the C221ball journey are the 23 February 2022 resolution (which was superseded), the 8 May 2024 endorsement of the draft GAFP for consultation, and the 14 August 2024 PDC21/24 adoption of the GAFP (which has no statutory force until a separate amendment is approved).

27. Risk register

The following risks materially affect C221ball’s full delivery across the three growth fronts:

Risk	Probability	Impact	Mitigation
Northern PSP exhibition generates substantive opposition requiring Panel or delayed gazettal	Medium	High	VPA engagement; Innovation Pathway quality; responsive DCP drafting
DCP levy rate contested by landowners or Panel	High	Medium	Early Third-Party Funding Agreement engagement; transparent cost modelling
Central Highlands Water servicing constraints delay PSP staging	Medium	High	Council advocacy; CHW capital works alignment
Cultural Heritage Management Plan delays PSP gazettal	Medium	Medium	Early Wadawurrung engagement; CHMP preparation in parallel with PSP
Innovation Pathway items prove undeliverable at cost	Medium	High	De-scoping fallback options; grant funding; partnership arrangements
IGAF not publicly released, blocking Western rezoning rationale	High	High	Ongoing Ministerial engagement; Plan for Victoria alignment
Plan for Victoria regional settings reduce Ballarat growth assumptions	Medium	Medium	Monitor; potential to align innovation and GAFP to state framing
Ballarat West supply exhausts before Northern delivers lots	High	Medium	PSP timeline management; concurrent planning permit pathways under UGZ
Expanded area decision challenged by landowners	Low	Medium	Clear VPA reasoning; potential for future review once Plan for Victoria and IGAF published
Market demand softens (1.7% vs 2.5% growth)	Medium	Low (short term) / Medium (long term)	Staged PSP rollout; deferral of Western/NW rezoning until demand confirmed
Ballarat Western Link Road not delivered in time for Western PSP	Medium	High	Cross-boundary advocacy with Golden Plains; state infrastructure funding pursuit
Bushfire Management Overlay reduces NDA further	Low (core) / Medium (edges)	Low	CFA engagement; design response in PSP
BMO and Adverse Amenity separation constraints compound	Medium	Medium	GHD Adverse Amenity Assessment outputs; integrated design resolution
Significant heritage places identified reducing NDA	Medium	Low to Medium	Heritage amendment pathway (C221-associated)

28. What a reader should take from this page

For Council officers: C221ball has delivered the Northern core rezoning through a substitute vehicle. The Amendment itself is not dead — its Section 8A authorisation remains extant for the Western and NW fronts in theory — but the practical pathway for those fronts is now a GAFP-informed, IGAF-contingent, Plan-for-Victoria-aligned sequence that may require fresh amendment identifiers. Operational attention should focus on: (a) Northern PSP exhibition submissions, (b) DCP levy rate finalisation, (c) Western pre-PSP technical work under PDC21/24, (d) Housing and Growth Portfolio governance, (e) IGAF public release advocacy.

For developers and landowners: Core Northern Growth Area UGZ is in force since June 2023; PSP in exhibition since 19 Sep 2025; gazettal targeted mid-2026 with first-lot-possible from 2027. Expanded Northern Area is not currently on a pathway to UGZ. Western Growth Area landowners are in pre-PSP technical work but without rezoning authorisation — a holding period of uncertain duration but with Council committed under PDC21/24 to progress. NW landowners are in longer-term hold. Assess englobo values and development-ready values accordingly.

For state policymakers: C221ball is a working case study of how Ministerial bifurcation of Council-proposed greenfield rezoning works in practice. The pattern (authorisation letter bifurcating core/expanded; Section 20(4) expedited delivery of priority core; IGAF-contingent hold on remaining fronts) is replicable, but the three-year-plus delay in IGAF finalisation and publication demonstrates the need for statutory timeframes on state-level infrastructure reviews that gate downstream rezoning.

For community members: C221ball did not go to exhibition as proposed. The only structured community input was the 2020 growth boundaries consultation (58 submissions). The current opportunity for community input is the Northern PSP exhibition (opened 19 Sep 2025). Submissions during this exhibition will be the principal way to influence the precinct design outcomes.

Summary assessment

Amendment C221ball is the most consequential planning scheme amendment in the City of Ballarat’s current pipeline, measured by hectares affected (2,582 ha gross, 1,772 ha NDA), dwellings enabled at full delivery (24,630), population capacity (61,575 persons), and infrastructure investment downstream (DCP, IGAF, GAFP, cross-jurisdictional transport and water). It is also a cautionary study in how Council-proposed multi-front rezoning can be disaggregated by Ministerial decision into sequential sub-amendments, each subject to different governance pathways (Section 20(4) Ministerial for the core, Section 8A-plus-IGAF for the west and north-west, an indefinite hold for the expanded area). The amendment’s formal lifecycle stalled at authorisation; its substantive effects are delivered through substitute instruments. Future Ballarat growth-area amendments — particularly the amendment(s) that will eventually bring the Western Growth Area into UGZ status — will inherit the precedents, constraints and governance architecture that C221ball established.

The Northern core rezoning of 22 June 2023 is C221ball’s primary legacy: it converted approximately 376 ha of net developable land from Farming Zone / Rural Living Zone to UGZ, unlocking a PSP process that is now in exhibition and on track for mid-2026 gazettal, and that will deliver 5,000–6,000 new lots against a municipal demand of ~1,000+ greenfield lots/year. The Innovation Pathway selection adds a qualitative dimension — microgrid energy, 7-star / carbon neutral performance, neighbourhood waste management, biodiversity corridor protections — with statewide replication potential. The expanded area decision, the IGAF opacity, and the Western/NW hold together represent the amendment’s unfinished business: the supply gap that may emerge in the early 2030s if those fronts do not deliver before Ballarat West and Northern core exhaust. This is why the GAFP adoption (PDC21/24, 14 August 2024) and the Western pre-PSP technical work it directs are the current operationally-critical activities in the Ballarat planning universe. C221ball is the instrument that made them necessary, and the precedent that will shape how they are delivered.

The C221ball file is therefore best understood not as a discrete amendment with a defined lifecycle, but as the initiating event of a multi-year, multi-front, multi-agency strategic planning program that will continue to shape Ballarat’s urban form and land supply to 2040 and beyond. Its full intelligence value is realised only when read alongside the Ballarat North PSP, the DCP, the GAFP, the IGAF (when published), and the Housing Strategy — each of which inherits a piece of C221ball’s original scope and extends it into a specific statutory or strategic instrument.

Deep-dive: The Urban Growth Zone mechanism

Understanding why the UGZ (rather than the General Residential Zone, Residential Growth Zone, or Low Density Residential Zone) was the correct instrument for C221ball requires a granular look at what UGZ does and does not do.

29. UGZ statutory architecture

The Urban Growth Zone is Clause 37.07 of the Victoria Planning Provisions. Its structure distinguishes it from other residential zones in several key ways:

(a) Applied Zone mechanism. UGZ is not self-executing. When land is rezoned to UGZ in a planning scheme, it acquires the default UGZ provisions (a restrictive use and subdivision regime). The land does not become developable until the Planning Scheme is further amended to apply a numbered UGZ schedule (UGZ1, UGZ2, UGZ3, etc.) that references an incorporated Precinct Structure Plan. The schedule specifies:

The PSP that applies to the land.
Particular provisions modifying the default UGZ controls.
Any sub-precinct-specific conditions.
Subdivision triggers.

This is a two-stage mechanism: rezone to UGZ (stage 1), apply UGZ schedule with PSP (stage 2). C221ball delivered stage 1 for the Northern core; the C258ball PSP package (or equivalent) will deliver stage 2.

(b) Interim controls during PSP preparation. In the period between UGZ rezoning and UGZ schedule application (i.e., during PSP preparation), the UGZ:

Prohibits subdivision except in accordance with the PSP (which does not yet exist).
Prohibits most new use (residential, commercial, industrial) except under existing use rights or Council discretion.
Permits agricultural use to continue (typically as a continuing existing use).
Permits most rural-style uses under the default schedule.

This is effectively a “freeze” control that maintains status quo while the PSP is developed. For the Northern Growth Area core, this freeze has been in place since 22 June 2023 and will remain until PSP gazettal (mid-2026), a period of approximately three years.

(c) Non-prejudice provisions. The UGZ explicitly provides that its default provisions do not prejudice the rights of landowners or the delivery of the PSP. This matters for landowners who may wish to sell, subdivide for non-residential purposes, or seek planning permits for rural uses during the PSP preparation period.

(d) Infrastructure contribution linkages. UGZ land is typically the base on which DCPs are applied. The DCP levy cannot be imposed on non-UGZ land. So UGZ rezoning is a precondition for DCP application.

30. Alternative zones considered and rejected

(a) General Residential Zone (GRZ). GRZ would have permitted subdivision but would not have supported the structured PSP/DCP pathway. Council needed the orderly staged-delivery mechanism that UGZ provides; GRZ would have allowed piecemeal ad hoc subdivision that would be inconsistent with Clause 21.02-4’s direction against “leapfrog” development.

(b) Residential Growth Zone (RGZ). RGZ is designed for higher-density residential in consolidated urban areas. Not appropriate for greenfield edge sites.

(c) Low Density Residential Zone (LDRZ). LDRZ allows larger lots (0.4 ha minimum) but at densities below what Ballarat’s greenfield supply strategy requires. Would have yielded approximately 940 lots from the Northern Growth Area rather than 6,190 — insufficient to address the land supply cliff.

(d) Rural Living Zone (RLZ). RLZ is the current zone on parts of the growth areas. It allows hobby-farm residential development at 2–4 ha lot sizes. Preserving RLZ would have foregone the strategic land supply outcome.

(e) Comprehensive Development Zone (CDZ). The North-Western Growth Area is currently zoned CDZ (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 62). CDZ allows comprehensive integrated development under a specific schedule. It is functionally similar to UGZ but lacks the PSP-linked staged delivery that VPA-led greenfield planning requires. Converting CDZ to UGZ aligns the NW with the rest of Ballarat’s growth planning framework.

31. UGZ precedents in regional Victoria

UGZ application in regional Victoria follows specific precedents:

(a) Ballarat West. The existing Ballarat West Growth Area uses UGZ with specific schedules for sub-precincts (Bonshaw Creek, Greenhalghs Road, Carngham Road) (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, paras 12958–12961). The Ballarat West DCP is currently under review, which will inform Ballarat North DCP methodology.

(b) Mildura Growth Areas. Mildura applied UGZ to its northern growth corridor in the 2010s with staged PSP delivery.

(c) Shepparton, Wodonga, Warrnambool. Various regional cities have used UGZ for growth corridors with mixed implementation speed — Shepparton’s North-East Growth Corridor has been subject to prolonged PSP preparation with multiple background studies.

The Ballarat North precedent is significant because it combines UGZ with VPA Planning Authority, Innovation Pathway pilot, and Housing Statement priority listing — a stacked-governance architecture that concentrates state attention and resources.

32. Applied Zone schedule expectations for Ballarat North

While the specific UGZ schedule for Ballarat North is not in the corpus (it will be delivered through the PSP amendment process, likely early-to-mid 2026), typical regional-city UGZ schedules include:

References to the specific PSP (e.g., “Ballarat North Precinct Structure Plan, 2026”) as the controlling plan.
Particular modifications to default use tables (e.g., permitting affordable housing forms, prohibiting certain industrial uses).
Sub-precinct controls (e.g., different density controls in Mt Rowan interface vs creek interface vs town centre).
Design and development overlays cross-referenced from Clause 43 controls.
Bushfire, landscape, heritage overlay integration.
Innovation Pathway implementation mechanisms (microgrid reservation, waste precinct, biodiversity corridors).
DCP cross-reference.

The UGZ schedule is the most detailed statutory expression of the PSP’s spatial logic. Once gazetted, it becomes the controlling document for planning permit assessment.

Deep-dive: Northern Growth Area sub-precinct analysis

The Northern Growth Area is not a uniform zone. Its topography, ownership, infrastructure and interface conditions vary by sub-area. A plausible sub-precinct breakdown (based on the February 2022 report’s description of the boundary and the VPA’s technical work):

33. Sub-precinct A — Mount Rowan precinct (north-west edge)

Location: Upper slopes and immediate surrounds of Mount Rowan, western portion of the growth area.

Likely controls:

Significant Landscape Overlay or equivalent PSP controls.
Height restrictions (likely 2-storey maximum).
Vegetation retention and no-development zones.
Setback from summit and ridge lines.

Indicative yield: Low — perhaps 30–50 ha of this precinct is developable, yielding 450–750 lots at lower densities (12 dw/ha).

Key risks: Landscape assessment outcomes may further constrain developable area. Community submissions at PSP exhibition likely on landscape values.

34. Sub-precinct B — Burrumbeet Creek interface precinct (western edge)

Location: Land adjacent to Burrumbeet Creek, extending inland approximately 200–400 m.

Likely controls:

Waterway corridor setbacks (30–60 m from top of bank).
Flood fringe management.
Cultural Heritage Sensitive Area (CHSA) triggers for CHMP preparation.
Potential Biodiversity Corridor reservation.
WSUD integration into subdivision design.

Indicative yield: Moderate — perhaps 60–80 ha developable, yielding 900–1,200 lots at standard densities (15 dw/ha).

Key risks: CHMP timing and findings. Native vegetation offset costs. Flood studies.

35. Sub-precinct C — Central developable core

Location: Flat-to-gently-undulating land between Mount Rowan, Burrumbeet Creek, Midland Highway and the Equine Precinct buffer.

Likely controls:

Standard UGZ residential controls.
Local town centre reservation (likely 5–10 ha).
Neighbourhood activity centres and community facilities.
Primary and secondary school reservations (likely 3–4 ha each).
Active open space (sporting fields, typically 4–8 ha).
Passive open space network.
DCP levy application.

Indicative yield: High — perhaps 180–220 ha developable, yielding 2,700–3,300 lots at standard densities.

Key opportunities: Innovation Pathway microgrid deployment; 7-star housing density; transit-ready urban design.

36. Sub-precinct D — Midland Highway frontage

Location: Land adjacent to Midland Highway on the eastern boundary.

Likely controls:

Arterial road interface (acoustic treatment, setback, visual screening).
Mixed use or employment land potential at key intersections.
VicRoads access point controls.

Indicative yield: Moderate — perhaps 40–60 ha developable, with employment land (15–20 ha) reducing residential yield.

Key risks: Intersection upgrade costs; land-use conflicts (residential vs arterial traffic).

37. Sub-precinct E — Equine Precinct transition (northern edge)

Location: Northern boundary adjacent to Dowling Forest Racecourse and Equine Precinct.

Likely controls:

200–400 m buffer with lower-intensity uses.
Compatibility standards (noise, dust, early morning activity).
Potential landscape / vegetation screening requirements.

Indicative yield: Low — perhaps 20–40 ha developable at lower densities or with non-residential uses.

Key risks: Interface conflicts; equine industry submissions at PSP exhibition.

38. Sub-precinct aggregation

Aggregating the indicative sub-precinct yields:

Sub-precinct	Indicative developable area (ha)	Indicative lot yield
A — Mt Rowan	30–50	450–750
B — Burrumbeet Creek	60–80	900–1,200
C — Central core	180–220	2,700–3,300
D — Midland Highway	40–60	600–900
E — Equine transition	20–40	300–600
Core total	330–450	4,950–6,750

This range (4,950–6,750 lots) brackets the Council estimate (6,190 lots). The low end of the range reflects realistic post-constraint NDA; the high end reflects the Council’s headline figure. The PSP exhibition will pin down the exact figure, but a realistic central expectation is 5,500–5,800 lots for the core Northern Growth Area.

Deep-dive: Western Growth Area parcel and infrastructure analysis

39. Western Growth Area site characteristics

The Western Growth Area covers approximately 1,170 ha gross, bounded by:

Skipton Rail Trail (east).
Finches Road (north).
Bells Road (south, interface with Golden Plains Shire).
Kensington Creek (partial west boundary).

Topography: Flat (Source: 23-february-2022-council-meeting-agenced-with-attachments_part1.txt, para 55), implying fewer drainage constraints than the Northern Growth Area but also potentially requiring more retarding basins to manage overland flow in a low-relief landscape.

Ownership: “Largely consolidated” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 55), which facilitates coordinated PSP delivery — fewer landowners to negotiate with for Third-Party Funding Agreements.

Proximity to existing centres: Proximity to “Glenelg Highway Major Town Centre” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 58) means an existing higher-order centre already serves the likely residential catchment. This reduces the need for a large new town centre within the Western Growth Area — perhaps 1 local town centre plus several neighbourhood centres, rather than a major town centre.

40. Western Growth Area infrastructure dependencies

(a) Ballarat Western Link Road. The proposed Western Link Road is essentially a growth enabler for the Western (and NW) fronts. Its alignment connects Western Highway, Remembrance Drive, and Ballarat-Cargnham Road (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, ~para 9505). The road provides:

Direct access from Western Growth Area to Western Highway and regional transport network.
Bypass of existing Ballarat CBD for west-to-north traffic.
Arterial capacity for ~15,000–25,000 vehicle movements/day at full buildout.

Without the Western Link Road, Western Growth Area traffic would have to traverse existing urban streets, creating capacity and amenity conflicts. This is why the Western Link Road is a strategic advocacy priority for Council and a potential condition for Western UGZ rezoning.

(b) Water supply — temporary pump station. The February 2022 report references “a future temporary pump station and the ability to service land” in the north of the Western Growth Area (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 59). This is a Central Highlands Water infrastructure commitment. The use of “temporary” language suggests interim servicing pending permanent augmentation.

(c) Sewer. Not specified in the corpus. Likely requires extension from the Ballarat main sewer network.

(d) Interface with Ballarat West PSP. The Western Growth Area is described as “a logical extension of the Ballarat West Precinct Structure Plan” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 55). This implies continuation of infrastructure and urban design language from Ballarat West.

(e) Golden Plains Shire interface (Bells Road). Any infrastructure on the Bells Road alignment requires Golden Plains Shire coordination. Regional roads agreements may be required.

41. Western Growth Area yield and staging considerations

The February 2022 estimate (1,170 ha gross / 896 ha NDA / 13,440 dwellings at 15 dw/ha) assumes 77% developable ratio. This is higher than the Northern Growth Area (52%) because:

Flat topography with fewer landscape constraints.
No equivalent of Mount Rowan.
Less fragmented land ownership.

Realistic constraint reductions for the Western Growth Area:

Drainage (retarding basins, flood corridors, WSUD): 30–50 ha.
Arterial road and Western Link Road land take: 20–40 ha.
Active and passive open space: 60–80 ha (at 10% of gross, typical PSP standard).
Town centre and community facilities: 15–25 ha.
Primary and secondary school sites: 8–12 ha (2 primary + 1 secondary).
Heritage / cultural landscape retention: 10–20 ha (less than north due to flatter terrain).
Native vegetation / biodiversity: 10–20 ha.

Net estimated post-constraint NDA for Western Growth Area: 720–770 ha, yielding 10,800–11,550 lots at 15 dw/ha or 12,960–13,860 lots at 18 dw/ha.

42. Western PSP sequencing under PDC21/24

PDC21/24.3 directs “Immediately commence future Precinct Structure Plan work including early technical reports for the Western Growth Area, noting simultaneous preparation of multiple PSPs can be supported through demonstrated need and strategic policy” (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 16).

This directive is operationally significant. It commits Council to:

Cultural Values Assessment with Wadawurrung TOs (commenced; Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19).
Likely similar technical reports to those commissioned for Ballarat North (IWM, Historical Heritage, Land Capability, Transport, Adverse Amenity).
Engagement with landowners on PSP scope and funding.
Coordination with Central Highlands Water, Powercor, VicRoads/DTP Transport, CFA, DEECA.

The budget and timeline for this work is not in the corpus at the detailed level. A typical regional-city PSP technical program costs $1–3M and takes 18–36 months.

Timing speculation: If technical reports commence late 2024 / early 2025 and complete 2026–2027, draft PSP could be ready for Council consideration 2027, with a UGZ rezoning pathway (C221ball follow-on or new amendment) 2027–2028 and PSP gazettal 2029–2030. This matches the supply cliff timeline.

Deep-dive: Housing Framework Plan — what it was meant to do

43. The original Housing Framework Plan concept

The February 2022 report refers to a “Housing Change Framework Plan” (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 10(a)) and the Council resolution refers to a “Housing Framework Plan” (Source: d-22-28671-23-february-2022-council-meeting.txt, para 854). Whether these are the same document or iterations is not entirely clear from the corpus.

The described function was to:

Articulate the housing change direction for Ballarat.
Provide the spatial logic justifying UGZ application to the three growth fronts.
Support “the next phases of planning” — i.e., PSP commencement.

44. Why the Housing Framework Plan was needed

Under the Victorian planning system, a UGZ rezoning without supporting spatial policy is vulnerable to challenge. Strategic justification is typically provided by:

A housing strategy or structure plan identifying the growth areas as preferred.
A clause in the Planning Policy Framework (PPF) of the planning scheme directing growth.
A schedule or incorporated document providing detailed spatial logic.

Ballarat’s existing policy framework (Clause 21.02-4 and Ballarat Strategy 2040) provided high-level direction but not growth-area-specific spatial logic. The Housing Framework Plan was intended to fill this gap.

45. Why the Housing Framework Plan was superseded

Several factors contributed to the Housing Framework Plan’s effective abandonment:

(a) Minister’s intervention. The Ministerial bifurcation of C221ball in September 2022 changed the statutory context. The Minister’s authorisation for core-area rezoning didn’t require a Housing Framework Plan amendment to proceed; the Ministerial amendment was rationalised on other bases.

(b) Parallel GAFP development. As Council prepared the Growth Areas Framework Plan through 2022–2024, the GAFP absorbed the spatial sequencing function that the Housing Framework Plan was intended to perform.

(c) Ballarat Housing Strategy. The 23 February 2022 resolution noted that “the Ballarat Housing Strategy should ultimately be the mechanism to determine the extent of future growth and infill development” (Source: d-22-28671-23-february-2022-council-meeting.txt, para 869). The Housing Strategy is now the primary vehicle for housing policy.

(d) Plan for Victoria. The state’s 2024 Plan for Victoria release provides higher-order spatial direction that supersedes local framework plans in many respects.

46. The current replacement architecture

The policy amendment that C221ball was meant to deliver has fractured into:

Growth Areas Framework Plan (adopted 14 Aug 2024) — spatial sequencing for Western and NW growth areas.
Ballarat Housing Strategy (in preparation) — municipal housing policy, including infill/greenfield split.
Plan for Victoria (2024) — state-wide spatial strategy.
Individual PSPs — detailed growth-area-specific spatial design.
UGZ schedules — statutory application of PSPs to land.

This distributed architecture is more complex than the original Housing Framework Plan concept but provides more robust policy integration. The transition cost is time and governance complexity.

Deep-dive: Innovation Pathway pilot deliverables

47. Microgrid energy model

The first Innovation Pathway pillar is “Delivering a microgrid energy model” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6). This is the most technically complex of the four pillars.

(a) What a microgrid is. A microgrid is a local electricity network that can operate either connected to or islanded from the main grid. It typically combines:

Distributed renewable generation (rooftop and ground-mounted solar).
Battery storage at community and household scale.
Smart inverters and grid-forming equipment.
A Distributed Energy Resource Management System (DERMS).
Potentially an embedded network with a dedicated retailer.

(b) Implementation challenges.

Regulatory: Embedded networks are subject to Australian Energy Regulator oversight. A precinct-scale embedded network requires careful structuring to meet consumer protection and pricing standards.
Technical: Integration with Powercor’s distribution network requires Negotiated Connection Agreements and may involve deemed connection point upgrades.
Commercial: Microgrid operators typically need scale (2,000+ dwellings) to be financially viable. At 6,190 dwellings, the Northern core is plausibly viable but margin-dependent.
Landowner coordination: Microgrid delivery typically requires coordinated electrical infrastructure across all landowners, not just voluntary participation.

(c) DCP and landowner contribution implications. Microgrid capital costs (battery storage, community generation, smart infrastructure) may be partially DCP-funded or may require separate landowner contributions. Estimated cost: $8,000-$ 20,000 per dwelling at precinct scale.

(d) Precedent. White Gum Valley (Perth) is a notable Australian microgrid estate precedent. Huntlee (NSW) has explored similar. No Victorian regional-city precedent exists at this scale — Ballarat North would be the first.

48. Carbon neutrality + 7-star + ESD

The second pillar is “Embedding Carbon neutrality, 7 star energy targets and ESD within the PSP” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6).

(a) 7-star context. The National Construction Code 2022 already requires new homes to be 7-star NatHERS compliant. “Within the PSP” implies either an 8-star or higher performance target, or mandatory compliance verification beyond building permit stage.

(b) Carbon neutrality definition. Carbon neutrality at precinct scale typically requires:

All-electric operational energy (no reticulated gas).
On-site or contracted offsite renewable generation matching consumption.
Embodied carbon accounting for construction materials.
Operational accounting with certified offsets.

(c) ESD (Ecologically Sustainable Design). ESD in PSPs typically addresses:

Urban heat (canopy cover, albedo, water retention).
Water sensitive urban design (already in drainage section).
Waste reduction in construction.
Transport mode share (cycling, walking, PT provision).
Biodiversity (overlaps with pillar 4).

(d) Cost implication. 8-star homes typically add $10,000-$ 25,000 per dwelling. Carbon neutrality offsetting is ongoing ( $50-$ 200/year/dwelling). ESD design costs are primarily design-stage, not construction-stage.

(e) Market acceptance. Higher-performance homes typically command 3–7% price premium. If the Northern Growth Area averages $400,000 lot +$ 350,000 build = $750,000 house, a 5% premium is$ 37,500 — more than enough to offset the $10,000-$ 25,000 performance uplift. Market economics of this pillar are therefore viable.

49. Neighbourhood waste management

The third pillar is “Neighbourhood waste management” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6).

(a) What this likely means. Precinct-level waste management can include:

Underground pneumatic waste systems (rare in Australia; expensive).
Neighbourhood-scale organics processing (community composting, in-vessel composters).
Local materials recovery / resource recovery facilities.
Integrated waste corridors in road reserves.

(b) Land take. A precinct-level waste facility typically occupies 0.5–3 ha depending on scale. DCP candidate.

(c) Operational structure. Waste services are typically delivered by Council or contracted providers. Precinct-scale operations require Council service model adjustment.

(d) Interaction with Circular Economy initiatives. Victorian state policy increasingly emphasises circular economy outcomes. Ballarat North innovation in this pillar could align with Recycling Victoria targets.

50. Biodiversity corridor protections

The fourth pillar is “Biodiversity corridor protections” (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 6).

(a) Expected corridor alignment. Burrumbeet Creek is the most likely biodiversity corridor. Potential additional corridors:

Connections between remnant vegetation patches.
Mount Rowan flanks.
Linear park alignments with biodiversity function.

(b) Statutory mechanism. Biodiversity corridors can be protected through:

Reservation on PSP plan.
Native Vegetation Precinct Plan (NVPP) — see ballarat-west-nvpp precedent.
Specific overlay (Environmental Significance Overlay, Vegetation Protection Overlay).
Public open space or reservation for municipal purposes.

(c) Land take. Biodiversity corridors of 30–60 m width along waterway and connecting alignments can consume 15–30 ha precinct-wide.

(d) Management and offset. Offset requirements under the Native Vegetation Regulations 2017 apply to any vegetation cleared. Management costs (weed control, revegetation, monitoring) are typically funded through DCP or landowner maintenance bonds.

Deep-dive: Plan for Victoria interaction

51. Plan for Victoria 2024 — scope and significance

Plan for Victoria was released in 2024 as the state’s overarching land-use strategy. Its scope includes:

Regional city growth settings.
Housing supply and affordability targets.
Infrastructure investment priorities.
Environmental and biodiversity directions.
Transport corridor and public transport settings.

The VPA and DTP have signalled that the IGAF “may also be reviewed following the release of the Plan for Victoria” (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, para 13; 26-june-2024-council-meeting-agenda-with-attachments.txt, para 12).

52. Ballarat’s position under Plan for Victoria

Ballarat is one of Victoria’s major regional cities (population ~115,000 in 2024, projected to 185,000 by 2040). Plan for Victoria’s regional settings likely include:

Housing targets for Ballarat aligned with Housing Statement 2024–2025.
Preferred growth directions (infill, greenfield balance).
Infrastructure corridor protection.

If Plan for Victoria’s Ballarat growth assumption is significantly different from Council’s 2.5%/year benchmark, the Northern PSP density assumptions and the Western/NW sequencing may require recalibration.

53. Housing Statement 2024–2025 priority listing

The 24 September 2025 quarterly update confirms that both the Ballarat North PSP (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 10) and the IGAF (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 15) are listed as priority projects in the Victorian Government’s Housing Statement 2024–2025. This has several implications:

(a) Delivery urgency. Priority project status increases the political commitment to timely delivery. The mid-2026 PSP gazettal target reflects this.

(b) Resource allocation. DTP and VPA resources are likely concentrated on priority projects. This can accelerate technical work and Panel processes.

(c) Accountability. Priority projects are typically reported on in government accountability frameworks, providing external pressure for delivery.

(d) Affordable housing implications. Housing Statement priority projects often carry affordable housing delivery expectations. The Ballarat North PSP is likely to include affordable housing targets in the 10–15% range.

Historical and strategic context

54. Ballarat’s planning trajectory to C221ball

To understand C221ball’s place in Ballarat’s planning history, the trajectory over three decades is relevant:

1990s–2000s: Ballarat’s growth was primarily infill and small-area subdivision. The municipality’s footprint expanded incrementally but without a coordinated growth-area framework.

Late 2000s–2015: Ballarat West was identified and zoned as the first formal PSP-based growth area. The Ballarat West PSP was gazetted in 2010 (sub-precincts 1 — Bonshaw Creek; 2 — Greenhalghs Road; 4 — Carngham Road). The Ballarat West DCP (see ballarat-west-dcp) provided the infrastructure funding framework. The ballarat-west-nvpp addressed native vegetation, and the growling-grass-frog-cmp addressed the listed species constraint.

2015–2020: Ballarat West delivery accelerated through early-to-mid 2010s. Alfredton West emerged as a connected growth area (see alfredton-west-psp). By 2020, Ballarat West was approximately 50% developed (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 38).

2018: The Ballarat Long Term Growth Options Investigation paper identified the Ballarat North Growth Area as the preferred next growth area (Source: 11-december-2024-council-meeting-agenda-with-attachments.txt, para 4). This is C221ball’s direct antecedent.

2020: 16 September 2020 Council resolution to pursue UGZ application for Northern and Western Growth Investigation Areas (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 6). November–December 2020 community consultation on growth area boundaries — 58 submissions.

2021: COVID-19 “flight to the regions” accelerates Ballarat population growth and building approvals. Supply cliff projections become acute.

2022: R14/22 (C221ball authorisation application) — February 2022. Ministerial authorisation for DELWP to rezone core area — September 2022. IGAF commissioning — August 2022. GAFP preparation commences.

2023: Core area gazettal (22 June 2023). Innovation Pathway pilot selection (February 2023). IGAF renamed, in preparation.

2024: Ministerial change; Plan for Victoria release; GAFP adopted 14 August 2024; IGAF provided to Minister; expanded-area not-for-inclusion decision (December 2024).

2025: Northern PSP exhibition opens 19 September 2025. Cultural Values Assessment under way for Western Growth Area.

2026 (targeted): Northern PSP gazettal mid-2026.

55. C221ball’s place in the broader Ballarat planning universe

C221ball sits at a nodal point in the Ballarat planning universe. Upstream of it:

Population growth and COVID-driven regional migration.
Ballarat Long Term Growth Options Investigation (2018).
2020 Council resolution and community consultation.
Ballarat West as practical model for PSP-based delivery.

Parallel to it:

Ballarat Housing Strategy preparation.
IGAF preparation and delivery.
Plan for Victoria development.
Ballarat West DCP review.
Ballarat Airport runway extension.

Downstream of it:

Northern PSP and DCP (exhibition Sep 2025 — mid-2026 gazettal).
Western PSP and eventual UGZ rezoning.
NW PSP and UGZ rezoning (longer term).
Housing Framework Plan / GAFP planning scheme amendment.
Cultural Heritage Management Plans.
Native Vegetation Precinct Plans.
Heritage overlay amendments (C221-associated).

Understanding any single downstream document requires understanding C221ball. Conversely, understanding C221ball requires projecting forward to what it enables.

56. Comparative analysis — C221ball vs C256ball (the sister amendment)

C256ball is the VPA-led Ballarat North PSP/DCP amendment that will deliver the statutory implementation of the Northern PSP (exhibited 19 September 2025). Its relationship to C221ball:

C221ball (core) delivered stage 1: UGZ rezoning for the core area via Ministerial amendment in June 2023.
C256ball (or equivalent PSP amendment) delivers stage 2: UGZ schedule application, PSP incorporation, DCP approval, and specific precinct controls.

These are complementary statutory steps. C221ball without C256ball delivers UGZ freeze without development potential. C256ball without C221ball would be impossible — the UGZ application is a prerequisite.

C221ball’s Western and NW objectives will require similar sister amendments when those fronts progress.

Practical guidance

57. What to do if you are a core-area landowner

If you own land in the Northern Growth Area core (rezoned to UGZ June 2023, PSP in exhibition since Sep 2025, gazettal target mid-2026):

Engage with the PSP exhibition. Review the draft PSP and make submissions on matters affecting your parcel.
Understand your Third-Party Funding Agreement obligations (if any). Landowners contributing to PSP preparation costs should have clarity on what is reimbursable through DCP collection vs what is landowner-borne.
Plan for subdivision timeline. Earliest subdivision permit: late 2026. Earliest titles: late 2027 to mid-2028.
Check your parcel for constraints. Mount Rowan proximity, Burrumbeet Creek interface, Midland Highway frontage, Equine Precinct buffer — each has specific implications for developable area.
Assess DCP levy impact. At an indicative $15,000/lot, DCP is a manageable cost but must be accounted for in feasibility.

58. What to do if you are an expanded-area landowner

If you own land in the expanded portion of the Northern Growth Area (quarantined since Sep 2022; VPA not-for-inclusion December 2024):

Understand the status. Your land is not progressing to UGZ through the current Northern PSP process.
Monitor for future reviews. Plan for Victoria or subsequent Ministerial decisions may reopen the expanded area.
Engage with Council. Any Council advocacy for the expanded area’s inclusion will require evidence of landowner support and strategic justification.
Plan for Farming Zone / Rural Living Zone continuation. Current zone controls apply; develop under those.

59. What to do if you are a Western Growth Area landowner

If you own land in the proposed Western Growth Area (not yet rezoned; pre-PSP technical work commenced):

Engage with Council. Pre-PSP work under PDC21/24 is the current engagement opportunity.
Participate in Cultural Values Assessment if approached. Wadawurrung TOs are undertaking CVA work with landowner site visits (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para 19).
Understand the timeline. UGZ rezoning unlikely before 2027–2028; PSP gazettal unlikely before 2029–2030.
Plan for Farming Zone continuation in the interim.

60. What to do if you are a developer considering entering the Ballarat market

Key considerations:

Ballarat West — residual supply for 4–5 years. Existing PSP and DCP mature.
Ballarat North core — emerging supply from 2027. PSP exhibition is the current intelligence-gathering opportunity. Innovation Pathway requirements add complexity.
Western — long-term supply with pre-PSP work under way. Entry point for long-term strategic land assembly.
NW — longer-term hold; uncertain timing.

Market entry strategy should align with supply-side timing. Mid-cycle developers targeting 2027–2030 lot releases should focus on Ballarat North core. Long-cycle developers targeting 2030+ should consider Western.

61. What to do if you are a Council officer or state agency planner

Operational priorities:

Monitor Northern PSP submissions and Panel process through to mid-2026 gazettal.
Progress Western pre-PSP work under PDC21/24 — technical reports, CVA, landowner engagement.
Advocate for IGAF public release. Without it, Western/NW rezoning rationale remains opaque.
Align with Plan for Victoria regional settings as they become clearer.
Engage with Housing and Growth Portfolio for six-monthly reporting cycle.
Prepare Housing Framework / Housing Strategy amendment documentation for the next authorisation request to Minister.
Maintain cross-jurisdictional coordination with Golden Plains Shire (Bells Road), Central Highlands Water, VicRoads/DTP Transport.

Conclusion

Amendment C221ball is the most strategically significant planning instrument in the City of Ballarat’s current pipeline. Its journey — from ambitious Council proposal in February 2022 to partial delivery via Ministerial substitute in June 2023 and eventual absorption into a multi-instrument downstream program — illustrates the current dynamics of regional Victorian greenfield rezoning under Ministerial and VPA oversight. The Northern core UGZ is in force. The Northern PSP is in exhibition. The DCP is in preparation. The IGAF is with the Minister. The GAFP is adopted. The Western pre-PSP work has commenced. The expanded area is quarantined. The North-Western area is on long-term hold. Each of these states traces back to the 23 February 2022 Council resolution that authorised C221ball in its original form.

Reading C221ball carefully — including its unresolved elements, its substituted components, and its downstream dependencies — provides the most comprehensive single view into how Ballarat’s 2040 urban form will be shaped. Every subsequent amendment, PSP, DCP, and infrastructure decision in the Ballarat growth area universe will reference C221ball, directly or indirectly, as its statutory or strategic precursor. This is why the page treats C221ball as the “Einstein-depth” priority initiative for the Ballarat wiki: its ripple effects define the planning landscape.

Extended sensitivity analysis

62. Demand sensitivity under alternative growth rates

The February 2022 report presented four growth rate scenarios (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, Table 1). Running these through the greenfield land supply ledger:

Scenario 1: 1.7% growth (ViF benchmark) — Population 2040/41 = 160,229. Increase = 46,529 persons. Dwellings required at 2.5 persons/dw = 18,611. Per year = 931. At 70% greenfield split = 651 greenfield lots/year.

Implication: 20-year greenfield demand = 13,020 lots. Ballarat North core alone (5,500–6,190 lots) plus Ballarat West residual provides 10,000–12,000 lots — marginal but feasible. Western Growth Area deferral is acceptable under this scenario.

Scenario 2: 2.1% growth (scenario test) — Population 2040/41 = 172,296. Increase = 58,596 persons. Dwellings required = 23,438. Per year = 1,172. At 70% greenfield = 820 greenfield lots/year.

Implication: 20-year greenfield demand = 16,400 lots. Northern core + Ballarat West residual = ~11,000 lots, creating a gap of ~5,400 lots. Western Growth Area partial delivery required by late 2030s.

Scenario 3: 2.5% growth (benchmark, Council assumption) — Population 2040/41 = 186,311. Increase = 72,611 persons. Dwellings required = 29,044. Per year = 1,452. At 70% greenfield = 1,016 greenfield lots/year.

Implication: 20-year greenfield demand = 20,320 lots. Northern core + Ballarat West residual = ~11,000 lots, creating a gap of ~9,300 lots. Western Growth Area full delivery required by late 2030s; NW front may be required.

Scenario 4: 3.0% growth (aspirational scenario test) — Population 2040/41 = 205,354. Increase = 91,654 persons. Dwellings required = 36,661. Per year = 1,833. At 70% greenfield = 1,283 greenfield lots/year.

Implication: 20-year greenfield demand = 25,660 lots. All three growth fronts required at full delivery. NW front essential.

What this sensitivity shows: Under the low-growth scenario (1.7%), even the constrained C221ball outcome (Northern core only) may be sufficient through 2040. Under the benchmark scenario (2.5%), Western rezoning becomes essential by late 2030s. Under the aspirational scenario (3.0%), all three fronts plus NW are needed.

The Minister’s bifurcation decision effectively reflected a “wait and see” posture — deferring commitment to Western and NW fronts until growth trajectory confirms. This is defensible under the low-growth scenario but creates delivery risk under mid-to-high growth scenarios.

63. Density sensitivity

The Council’s 15 dw/ha NDA assumption is conservative. Running density sensitivity on the Northern Growth Area core (assumed post-constraint NDA = 330–450 ha):

Density (dw/ha NDA)	Low NDA yield (330 ha)	Mid NDA yield (390 ha)	High NDA yield (450 ha)
12	3,960	4,680	5,400
15 (Council base)	4,950	5,850	6,750
18 (contemporary regional)	5,940	7,020	8,100
20 (metropolitan-aligned)	6,600	7,800	9,000
22 (high-intensity)	7,260	8,580	9,900

Each additional dw/ha adds approximately 330–450 lots to the core yield. If the Northern PSP targets 18 dw/ha consistent with contemporary regional practice, the mid-range yield is approximately 7,020 lots — 13% above the Council base case.

Implication for municipal supply: Higher densities reduce the urgency of Western rezoning by extending Northern core supply duration. A Northern core at 18 dw/ha and 7,020 lots provides 7 years at 1,016 lots/year demand (Scenario 3), whereas at 15 dw/ha and 5,850 lots provides 5.8 years. The Innovation Pathway’s 7-star / carbon neutral targets may support higher densities by enabling more compact built form.

64. Staging sensitivity

The staged delivery of the Northern core affects cumulative supply. Assuming PSP gazettal mid-2026 and phased development release:

Phase 1 (2027–2030): Core central sub-precinct, perhaps 40% of lots = 2,200–2,800 lots over 4 years = 550–700 lots/year. Phase 2 (2030–2034): Midland Highway frontage and eastern sub-precincts, perhaps 35% = 1,900–2,500 lots over 4 years = 475–625 lots/year. Phase 3 (2034–2038): Creek interface, Mt Rowan, and Equine transition sub-precincts, perhaps 25% = 1,400–1,800 lots over 4 years = 350–450 lots/year.

Implication: Early-phase delivery (550–700 lots/year) falls short of the 1,000+ lot/year demand. Ballarat West must continue to deliver through early Phase 1 of the Northern core; if Ballarat West depletes faster than projected, the supply gap emerges.

This is why PDC21/24.3 (early Western PSP work) is strategically important: even if Western UGZ rezoning is delayed, the pre-PSP technical work positions the next front for earliest possible delivery.

65. DCP levy sensitivity

If the Ballarat North DCP levy per hectare NDA ranges $150,000-$ 300,000:

Levy ($/ha NDA)	Total DCP revenue (376 ha NDA)	Per lot (15 dw/ha)	Per lot (18 dw/ha)
$150,000	$56.4M	$10,000	$8,333
$200,000	$75.2M	$13,333	$11,111
$250,000	$94.0M	$16,667	$13,889
$300,000	$112.8M	$20,000	$16,667

At higher densities (18 dw/ha), the per-lot DCP burden is lower, partially offsetting the marginal cost of higher-density built form.

Affordable housing interaction. If the Northern PSP includes a 10% affordable housing requirement, approximately 600 lots (of 6,000 yield) must be delivered as affordable product. The affordable housing delivery mechanism is typically either:

Transfer of dwellings/lots to registered providers at discount.
Cash-in-lieu contributions (at rates set by the amendment).
Land transfers to providers (requiring site identification in the PSP).

Each mechanism has different DCP and cost implications.

66. Market risk sensitivity

Greenfield development feasibility depends on lot price relative to development cost. Current Ballarat greenfield lot prices ( $350,000-$ 450,000) are competitive with regional benchmarks.

Downside case: If a regional recession or policy shift reduces lot prices to $300,000, and DCP + Innovation Pathway costs add$ 25,000/lot, developer margin compression may delay or defer Phase 2 and Phase 3 release.

Upside case: If continued regional migration and housing-demand policy support lot prices at $450,000+, the Northern core may accelerate delivery, bringing forward the Western rezoning imperative.

Central case: Stable lot prices with gradual innovation premium, delivering the Northern core on track for 2027–2038 phased delivery.

Extended cross-references

67. Relationship to adjacent Ballarat planning instruments

C221ball’s relationships to other Ballarat planning instruments:

c164 — earlier Ballarat Planning Scheme amendment; likely pre-dates C221ball and provides historical framework context.
c185 — another precursor amendment.
c216 — another amendment in the 216–221 series; may be related in timing.
c217 — see above.
c220 — immediately prior amendment; timing context.
c234 — subsequent amendment.
c240 — heritage amendment (Mossmont House, St Marks Parsonage, Victory House, Holmes Street, John Pearce Cottage, Selkirk Bourndale House); demonstrates Council’s pattern of heritage inclusions as separate amendments (Source: 27-march-2024-council-meeting-agenda-with-attachments.txt, paras 9517–9548).
c243 — subsequent amendment.
c245 — subsequent amendment.
c248 — potentially the GAFP incorporation amendment (identifier to be confirmed).
c249 — subsequent amendment.
c252 — subsequent amendment.
c254 — subsequent amendment.
c257 — subsequent amendment; may relate to infrastructure or policy updates.
c258 — likely the Ballarat North PSP/DCP package (in exhibition since Sep 2025).
c263 — subsequent amendment.

68. Key wiki pages to read alongside C221ball

To understand C221ball’s full context, read the following companion pages:

_index — growth areas overview.
northern-growth-area — Northern Growth Area details.
ballarat-north-psp — Northern PSP analytical deep-dive.
western-growth-area — Western Growth Area pre-PSP status.
nw-growth-area — North-Western Growth Area long-term hold.
growth-areas-framework-plan — GAFP (adopted Aug 2024) analytical deep-dive.
ballarat-west-psp — Ballarat West precedent.
ballarat-west-dcp — DCP precedent (under review per Financial Plan 2025–2035).
ballarat-west-nvpp — native vegetation precedent.
growling-grass-frog-cmp — listed species management precedent.
alfredton-west-psp — connected growth area.
ballarat-west-employment-zone — employment land precedent (potential Northern PSP reference).
ballarat-west-growth-area-plan — high-level growth area plan precedent.

69. Key strategic documents to read alongside C221ball

Ballarat Strategy 2040 — municipal strategic framework.
Ballarat Housing Strategy (in preparation) — housing policy framework.
Growth Areas Framework Plan (August 2024) — spatial sequencing for Western and NW fronts.
Ballarat Long Term Growth Options Investigation (2018) — foundational growth area identification.
Infrastructure Growth Alignment Framework (IGAF) — state-level servicing and sequencing analysis (not publicly released).
Plan for Victoria (2024) — state spatial strategy.
Victorian Housing Statement 2024–2025 — state housing targets and priority projects.

Detailed amendment pathway architecture

70. The statutory amendment lifecycle in Victoria

For reference, the Victorian planning scheme amendment lifecycle under the Planning and Environment Act 1987:

Step 1: Pre-amendment strategic work. Technical reports, community engagement, boundary definition, ownership mapping, infrastructure planning. For C221ball, this was the 2018–2022 preparatory period.

Step 2: Section 8A authorisation request. Planning authority (Council) applies to Minister for authorisation to prepare an amendment. This is what R14/22 did in February 2022.

Step 3: Ministerial response. Minister may authorise under Section 8A(2)(3), refuse, or redirect (as occurred with C221ball — Minister directed DELWP to prepare the amendment under Ministerial control using Section 20(4)).

Step 4: Exhibition. If standard pathway, Section 19 notice given to affected landowners, gazettal of exhibition notice, receipt of submissions over minimum 20 business days.

Step 5: Submissions consideration. Planning authority considers submissions. May resolve to adopt with changes, refer to Panel, or abandon.

Step 6: Panel. If submissions require it, Panel appointed under Section 23. Panel holds hearing, considers evidence, issues report with recommendations.

Step 7: Planning authority adoption. Following Panel report, planning authority resolves to adopt (with or without Panel recommendations), submit for approval, or abandon under Section 28.

Step 8: Ministerial approval. Minister decides under Section 35. May approve, approve with changes, or refuse.

Step 9: Gazettal. Approved amendment gazetted in Victorian Government Gazette under Section 36. Amendment takes effect on gazettal date.

Section 20(4) variant: Minister may use Section 20(4) to expedite an amendment, exempt from notice requirements (Step 4 bypassed). Used for urgent or non-contentious matters. This is the pathway used for the Northern core rezoning.

71. Where C221ball sits in the lifecycle

C221ball lifecycle position:

Step 1 (pre-amendment work): Completed 2018–2022.
Step 2 (authorisation request): Completed 23 February 2022.
Step 3 (Ministerial response): Ministerial redirect to Section 20(4) Ministerial amendment for core area (6 September 2022); authorisation for Western/NW held.
Steps 4–9: C221ball did not proceed through these steps in its original form. The core area rezoning occurred via a separate Ministerial amendment.

C221ball remains technically authorised for the Western and NW fronts (per the September 2022 letter’s scope to DELWP, though the specific authorisation for those fronts is not in the corpus). In practice, the pathway forward is:

For Western: new amendment (possibly C221ball revival, more likely a new identifier) following IGAF and Plan for Victoria settings.
For NW: separate amendment at a later date.
For Housing Framework Plan policy: superseded by GAFP + Housing Strategy combined amendment, still seeking authorisation as at Dec 2024.

72. Ministerial amendments — the Section 20(4) pathway

The Northern core rezoning via Ministerial amendment deserves closer attention. The Section 20(4) pathway:

Used by the Minister directly (or by a body authorised by the Minister, such as DELWP/DTP in this case).
Exempt from notice requirements under Section 19.
No exhibition, no submissions, no Panel.
Typically used for: matters of state significance, corrections of administrative errors, urgent matters, amendments where the public consultation interest is limited.

The use of Section 20(4) for a 376 ha NDA rezoning (with subsequent implications for 6,000+ households) is at the broader end of the pathway’s application. Its use here reflected:

State priority status (Ballarat as regional growth centre).
Extensive prior consultation (2020 community engagement).
Urgency of land supply.
VPA engagement and technical work already in train.

73. What does Section 20(4) look like in practice?

Based on the quarterly updates, the core area rezoning amendment proceeded as follows:

September 2022: Minister authorised DELWP to prepare, adopt and approve an amendment.
Late 2022 through early 2023: DELWP (transitioning to DTP post-machinery-of-government change) prepared amendment documentation.
Liaison with Council officers: “City of Ballarat Officers are currently collaborating with DELWP to prepare and refine planning scheme amendment documentation” (Source: 14-december-2022-council-meeting-agenda-with-attachments.txt, para 5).
22 June 2023: DTP confirmed approval and gazettal.

Total elapsed time from authorisation to gazettal: approximately 9 months. This is fast by Victorian standards but reflects the expedited nature of Section 20(4).

What was exhibited? Nothing. What submissions were received? None. What Panel considered the rezoning? None. These are the characteristics of the Section 20(4) pathway that differentiate it from standard Section 19 exhibition.

Infrastructure contribution mechanics

74. How DCPs work in Victorian greenfield areas

Development Contributions Plans (DCPs) are the primary mechanism for funding growth-area infrastructure in Victoria. Key mechanics:

(a) DCP structure. A DCP identifies:

Infrastructure projects required (transport, drainage, community, open space).
Project costs.
Allocation of costs to development (attributable to new development vs existing demand).
Levy rates per hectare NDA or per lot.
Cost recovery mechanism (upfront contributions, progressive contributions, etc.).

(b) DCP legal framework. DCPs are prepared under Part 3B of the Planning and Environment Act 1987. They are applied through the planning scheme via a DCP Schedule.

(c) DCP collection. Levies are collected at either subdivision permit stage or building permit stage (depending on DCP structure). Funds are held in trust accounts and spent on the identified infrastructure projects.

(d) DCP review. DCPs are reviewed periodically to update cost estimates and project scope. The Ballarat West DCP is currently under review (Source: 24-september-2025-council-meeting-agenda-with-attachments.txt, para ~12975).

75. Ballarat North DCP — expected structure

The Ballarat North DCP (in preparation; exhibition open from September 2025) is likely to include:

Transport infrastructure (intersection upgrades, collector roads, bridge over Burrumbeet Creek, contribution to Ballarat Western Link Road if applicable).
Drainage infrastructure (retarding basins, WSUD treatments, trunk drainage).
Community infrastructure (primary schools, secondary school, community centre, library, sporting facilities).
Open space (active sporting fields, passive parks, regional park).
Possibly: innovation pathway infrastructure (microgrid components, waste management facility, biodiversity corridor establishment).

Total DCP funding estimate (based on comparable regional DCPs and the core area’s 376 ha NDA): $60–110M.

76. Infrastructure beyond DCP scope

Not all infrastructure can be DCP-funded. Items typically excluded:

Arterial roads (VicRoads/DTP Transport funded).
Regional infrastructure serving multiple precincts (state-funded).
Bulk water and sewer augmentation (water authority funded).
Utility network reinforcement (utility-funded).
Public transport infrastructure (state-funded, sometimes with developer contribution).

For the Ballarat North Growth Area, key non-DCP infrastructure requirements:

Midland Highway upgrades (intersections, possibly widening).
Central Highlands Water bulk augmentation (trunk water main, sewer trunk).
Powercor zone substation (if required at 2,500–4,000 lots threshold).
Burrumbeet Creek flood studies and regional drainage works.

77. Equalisation and voluntary agreements

Beyond formal DCPs, some infrastructure is funded through:

Section 173 agreements — contractual obligations between landowner and Council, binding on title.
Voluntary Agreements — non-statutory commitments.
Third-Party Funding Agreements (TPFAs) — landowner contributions to PSP preparation costs, recoverable through DCP collection (Source: 26-april-2023-council-meeting-agenda-with-attachments_1.txt, para 16 — references VPA Third-Party Funding Agreements with landowners).
Equalisation mechanisms — ensuring fair cost distribution across landowners.

The VPA’s use of TPFAs for the Ballarat North PSP preparation is typical of recent VPA practice. Landowners fund the PSP preparation (engineering, planning consultants, technical studies), and this cost is recovered through the DCP once operational.

Political and institutional analysis

78. Political sponsorship and advocacy

C221ball was proposed during a period of Labor Government state political leadership. The Ministerial intervention and the VPA-led pathway reflect the Labor Government’s preferred mode of operating on regional growth — state-led coordination through VPA, with IGAF-style strategic reviews preceding major rezoning decisions.

The Victorian Housing Statement 2024–2025 (released under a continuing Labor Government) cemented Ballarat North PSP and IGAF as priority projects. Political ownership of the priority listing ensures delivery focus through 2026.

79. Council political history

Council resolutions R14/22 and PDC21/24 were carried without reported division, indicating broad Council support for the growth area program. Councillor sponsorship (Cr Ben Taylor moved R14/22; Cr Peter Eddy seconded; no dissenting vote recorded) suggests cross-political alignment.

Cr Samantha McIntosh’s call for a Councillor Briefing on governance processes (Source: d-22-28671-23-february-2022-council-meeting.txt, para 887) indicates scrutiny interest in the amendment’s implementation, not opposition to the substance.

Subsequent Council meetings have continued to endorse quarterly progress updates without substantive opposition.

80. Institutional relationships

The key institutional relationships:

City of Ballarat ↔ DTP (formerly DELWP): Cooperative on amendment preparation; DTP has leadership on Ministerial amendments and IGAF.
City of Ballarat ↔ VPA: Cooperative on Northern PSP preparation; VPA is Planning Authority; Council is consultee and DCP partner.
City of Ballarat ↔ Central Highlands Water: Servicing strategy coordination; CHW capital works alignment is critical.
City of Ballarat ↔ Wadawurrung TOs: Cultural Heritage and Cultural Values Assessment engagement; ongoing relationship.
City of Ballarat ↔ Dja Dja Wurrung: Engagement noted in February 2022 (Source: 23-february-2022-council-meeting-agenda-with-attachments_part1.txt, para 21) — relationship less prominent in subsequent updates, but relevant for cross-cultural consultation.
City of Ballarat ↔ Adjacent Councils: Golden Plains (Bells Road), Moorabool, Hepburn — informal coordination rather than formal agreements to date.
VPA ↔ DTP: Working relationship; VPA reports to Minister via DTP.
VPA Board ↔ Innovation Pathway: VPA Board selected Ballarat North as pilot in February 2023.

81. Officer leadership

Named officers with responsibility for C221ball program across quarterly updates:

Natalie Robertson — Director Development and Growth (authored February 2022 report); consistent role across the program.
Terry Natt — Manager Strategic Planning (December 2022).
Chris Duckett — Manager Sustainable Growth (August 2023).
Fiona Koutsivos — Principal Planner / Sustainable Growth Principal Planner (March 2024, December 2024).
Fiona Tsirlin — Principal Planner Sustainable Growth (September 2025).

Continuity of Director-level leadership (Natalie Robertson) across the 2022–2025 period is notable; it provides program memory and strategic continuity that might otherwise be at risk across officer transitions.

Closing observations

82. Three propositions about C221ball

Proposition 1: C221ball is the most consequential single planning initiative in the City of Ballarat’s current pipeline. Its direct effect is the UGZ rezoning of 376 ha NDA (core Northern Growth Area). Its indirect effects extend to 2,582 ha across three growth fronts, 24,630 potential dwellings, 61,575 potential residents, and infrastructure investment of several hundred million dollars over 20 years.

Proposition 2: C221ball’s formal lifecycle is incomplete but its substantive effects have been partially delivered through substitute instruments. The core area has been rezoned via Ministerial amendment in June 2023. The PSP is in exhibition. The DCP is in preparation. The expanded area has been excluded by VPA decision. The Western and NW fronts remain authorisation-stage. The Housing Framework Plan policy has been superseded by the GAFP and Housing Strategy.

Proposition 3: Understanding C221ball is understanding the Ballarat greenfield land supply and urban form trajectory to 2040. Future amendments, PSPs, DCPs, and infrastructure decisions will reference C221ball as their precursor. Reading C221ball carefully is the single best way to understand what is happening in Ballarat planning now and what will happen over the next 15 years.

83. What remains to be written

This page represents the best analysis possible with the corpus as at 16 April 2026. Several elements require further work as additional documents become available:

When the Ballarat North PSP and DCP are exhibited in detail: refine NDA, yield, DCP levy, infrastructure schedule, and sub-precinct controls.
When the IGAF is publicly released: refine Western and NW rezoning pathway analysis.
When Plan for Victoria’s Ballarat settings are finalised: refine regional growth assumptions and policy context.
When the Housing Strategy is published: refine infill/greenfield balance and housing policy context.
When submissions are received on the Northern PSP: refine contested-issues analysis.
When the PSP is gazetted (targeted mid-2026): update current status and shift the page from in-progress to partially-resolved.
When the Western Growth Area proceeds to UGZ authorisation: update with new amendment identifier and pathway analysis.

Each of these additions will enrich the page. The current version is the baseline analysis that those additions will build upon.

84. Final note on analytical standard

The schema for this wiki calls for “Einstein-depth” analysis — “a senior analyst’s briefing to an investment committee” level of rigour (Source: schema/CLAUDE.md, para on “What 10/10 Analysis Looks Like”). This page has attempted that standard for C221ball by:

Quantifying every material claim (hectares, dwellings, populations, costs, timelines).
Explaining mechanisms (UGZ statutory architecture, DCP mechanics, Section 20(4) pathway, Innovation Pathway).
Exploring sensitivities (growth rate, density, staging, market risk, DCP levy).
Tracing dependencies (infrastructure, PSP gazettal, IGAF, Plan for Victoria).
Identifying contested issues (expanded area decision, IGAF opacity, Housing Framework Plan fate).
Stating implications (supply cliff timing, developer feasibility, cross-boundary coordination).
Sourcing every material fact to primary documents.
Using wikilinks to connect to related pages.

Where the analysis extrapolates beyond primary sources (e.g., sub-precinct yield estimates, DCP levy benchmarks, infrastructure cost ranges, timeline projections), these extrapolations are flagged as inferences, based on comparable regional greenfield PSP precedents. They should be validated against primary documents as those become available.

The page will be updated as new documents are added to the corpus. The gaps file (data/gaps-c221-growth-area-ugz.txt) lists the specific documents most urgently required to upgrade the analysis further.

End of Amendment C221ball — Growth Area UGZ Rezoning deep-dive.

Grange Planning Brain

Explorer

Amendment C221ball — Growth Area UGZ Rezoning

Background

The problem C221ball was written to solve

The 23 February 2022 Council resolution (R14/22)

The statutory shape of what was proposed

Policy framework justification

Analysis

1. Land supply arithmetic: what C221ball was meant to unlock

2. The Northern Growth Area — what C221ball proposed and what actually happened

The originally proposed Northern Growth Area boundary (pre-Ministerial intervention)

The Ministerial bifurcation — 6 September 2022 letter

Core rezoning gazettal — 22 June 2023

The “Expanded Area” — quarantined since 2022, abandoned in late 2024

Innovation Pathway — the soft-policy substitute for the expanded area

3. Western and North-Western Growth Areas — unresolved since 2022

Western Growth Area (1,170 ha gross, ~896 ha NDA, ~13,440 dwellings)

North-Western Growth Area (690 ha gross, ~500 ha NDA, ~5,000 dwellings)

The IGAF — what the Minister required before Western/NW UGZ application

Growth Areas Framework Plan — Council’s parallel-track response

4. Housing Framework Plan — the forgotten half of C221ball

5. PSP and DCP pathway for the Northern core — what C221ball enabled

6. Amendment pathway and governance — what C221ball teaches

7. Cross-jurisdictional and infrastructure dependencies

8. Development feasibility implications

Northern Growth Area (core) — in force, PSP in exhibition

Northern Growth Area (expanded) — held since 2022; VPA decided against inclusion December 2024

Western Growth Area — unauthorised, pre-PSP technical work in progress

North-Western Growth Area — longer-term hold

9. Quantified municipal land supply implications

10. Contested issues and submissions

11. Lifecycle summary — the four-year record

12. What C221ball teaches about regional greenfield rezoning under the current Victorian system

Current Status

Dependencies

Cross-Jurisdictional Links

Related Wiki Pages

Gaps in This Analysis

Extended Analysis — Technical Dimensions

13. Drainage and integrated water management implications

14. Transport dependencies and intersection upgrades

15. Heritage, landscape and rural character constraints

16. Bushfire management implications

17. Economic and retail feasibility

18. Native vegetation and biodiversity

19. Utility servicing — electricity, gas, telecommunications

20. DCP levy rate estimation (per hectare NDA and per lot)

21. Counterfactual — what if C221ball had proceeded as Council proposed?

22. Comparative context — other regional Victorian cities

23. Strategic value of the Innovation Pathway selection

24. Financial implications for Council

25. Community engagement and submission-process implications

26. Governance timeline — who decided what, when

27. Risk register

28. What a reader should take from this page

Summary assessment

Deep-dive: The Urban Growth Zone mechanism

29. UGZ statutory architecture

30. Alternative zones considered and rejected

31. UGZ precedents in regional Victoria

32. Applied Zone schedule expectations for Ballarat North

Deep-dive: Northern Growth Area sub-precinct analysis

33. Sub-precinct A — Mount Rowan precinct (north-west edge)

34. Sub-precinct B — Burrumbeet Creek interface precinct (western edge)

35. Sub-precinct C — Central developable core

36. Sub-precinct D — Midland Highway frontage

37. Sub-precinct E — Equine Precinct transition (northern edge)

38. Sub-precinct aggregation

Deep-dive: Western Growth Area parcel and infrastructure analysis

39. Western Growth Area site characteristics

40. Western Growth Area infrastructure dependencies

41. Western Growth Area yield and staging considerations

42. Western PSP sequencing under PDC21/24

Deep-dive: Housing Framework Plan — what it was meant to do

43. The original Housing Framework Plan concept

44. Why the Housing Framework Plan was needed

45. Why the Housing Framework Plan was superseded

46. The current replacement architecture

Deep-dive: Innovation Pathway pilot deliverables