title: Infill Housing Framework — Change Areas, Urban Renewal & the 50:50 Target council: ballarat state: vic category: strategy classification: MAJOR status: adopted (strategy); not implemented (planning scheme) last_compiled: 2026-04-16 source_docs:

housing-strategy-2041.txt
ballarat-municipal-housing-capacity-assessment-tract-2022-extracted.txt
ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt
ballarat-infill-uptake-analysis-sgs-2024.txt
neighbourhood-character-study.txt
affordable-housing-position-statement-final-2022.txt
social-and-affordable-housing-action-plan-july-2024.txt
ballarat-strategy-2040.txt
ballarat-west-growth-area-housing-and-growth-enabling-infrastructure-bnif.txt

Infill Housing Framework — Change Areas, Urban Renewal & the 50:50 Target

The 50:50 infill/greenfield dwelling target — first set in the ballarat-strategy-2040 (July 2015) and reiterated in the housing-strategy-2041 (August 2024) — is the single most consequential residential planning policy in the City of Ballarat, because it determines the rate at which greenfield land is consumed, the timing of new PSPs, the municipality’s capital works profile, and the built-form trajectory of every established neighbourhood with an accessibility rating at or above 70%. After a decade of pursuing this target the revealed split has moved further from it: from 60/40 greenfield/infill in 2019 to an average of 70/30 across 2019–April 2024, peaking at 77/23 in 2022 and settling at 68/32 in the first four months of 2024. This page quantifies the mechanisms intended to close that gap, traces the dependency chain that blocks delivery, and identifies the specific structural features of the Ballarat housing market that make achievement of the target difficult on the trajectory assumed by the strategy. The stakes are material: under the Tract Municipal Housing Capacity Assessment (2022), if infill share stays at 20% (close to current performance), zoned greenfield land lasts only 18 years — below the 15-year minimum after ordinary approvals friction — forcing Council either to accept the infill target is aspirational and rezone additional greenfield, or to implement the regulatory, structure-planning and infrastructure programs needed to actually shift the split.

Background

The target’s origin — Ballarat Strategy 2040 (2015)

The 50:50 infill/greenfield target was not introduced by the 2024 Housing Strategy. It was adopted in the ballarat-strategy-2040 (Today, Tomorrow, Together: The Ballarat Strategy, adopted July 2015), which observed at the time of adoption that approximately 40% of new housing was occurring in established areas and sought to increase this to 50%. (Source: housing-strategy-2041.txt; affordable-housing-position-statement-final-2022.txt)

The 2015 Strategy supported infill development “in appropriate areas subject to character analysis, with further actions seeking the prevention of ad hoc greenfield residential development and advocating for the delivery of affordable housing. It identifies a target for future dwelling supply split 50/50 between established and greenfield areas.” (Source: housing-strategy-2041.txt) The target therefore predates the 2024 Housing Strategy by nine years, and the 2024 Strategy inherits — rather than creates — the policy aspiration.

The intervening decade — what changed the conditions

Between 2015 and 2024 several factors materially altered the conditions under which the 50:50 target was operating:

The Ballarat West PSP (adopted October 2016, after the 2015 Strategy) provided approximately 8,800 lots of statutory greenfield supply at 15 lots/ha maximum take-up, with infrastructure delivered via a DCP. (Source: housing-strategy-2041.txt, Table 9)
The Alfredton West PSP (2011) was already operational and added approximately 800 lots. (Source: housing-strategy-2041.txt)
The Northern Growth Area Core Area was identified for approximately 6,600 lots in the pipeline, though unzoned at that time. (Source: housing-strategy-2041.txt)
VIF projections understated growth. The 2019 VIF projections used for early strategy drafting predated both the pandemic and the 2021 Census. The most recent VIF available during strategy preparation did not reflect post-COVID migration, living arrangement changes, or housing market behaviour. (Source: housing-strategy-2041.txt)
The 2021 Census recorded 113,482 people living in 50,204 dwellings, with housing stock having grown by 14,049 dwellings between 2006 and 2021 at an average 2.1% per annum. (Source: ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt)
Building permits peaked at 2,013 in 2021 with greenfield capturing 1,426 (71%) and infill 587 (29%) — the highest absolute volume but one of the most unbalanced greenfield-heavy years. (Source: housing-strategy-2041.txt, Table 8)
Victoria’s Housing Statement (September 2023) committed the State to 70:30 infill/greenfield and introduced Amendments VC242 (Cl 53.22 / 53.23 — significant economic and residential development) and VC243 (Future Homes, permit exemption for single dwellings on lots ≥300sqm, VicSmart on smaller lots). These came into effect 20 September 2023. (Source: housing-strategy-2041.txt; neighbourhood-character-study.txt §2.3)
The State’s draft Plan for Victoria housing target for Ballarat is 46,900 additional homes by 2051. (Source: housing-strategy-2041.txt)

The 2024 Strategy’s operational translation

The Housing Strategy 2041 (August 2024) operationalises the target through a Housing Framework Plan that classifies all residential land into change areas and identifies six urban renewal sites with a combined theoretical yield of 8,643 dwellings at an assumed 35 dwellings per gross hectare. (Source: housing-strategy-2041.txt, Table 11)

The Strategy was prepared in accordance with Planning Practice Note 90 (Planning for Housing), which requires local councils to plan for at least 15 years of population growth and establish a Residential Development Framework (RDF). The RDF’s three components under PPN90 are: the Housing Strategy itself; the Neighbourhood Character Strategy; and the Residential Change Areas. PPN91 (Using Residential Zones) then governs how the change areas translate into zones (LDRZ / TZ / NRZ / GRZ / RGZ / MUZ). (Source: housing-strategy-2041.txt §Policy Context; neighbourhood-character-study.txt §2.3)

Strategy preparation timeline (stage by stage)

The project proceeded over four stages (Source: housing-strategy-2041.txt, Figure 1):

Stage	Activity	Period
1	Housing Discussion Paper + community consultation	2021
2	Draft Housing Strategy + Neighbourhood Character Study	April 2022 – August 2023
3	Consultation on draft Strategy and NCS	August 2023 – October 2023
4	Preparation of final Strategy	November 2023 – June 2024
—	Adoption	August 2024
—	Planning scheme amendment to implement	Not commenced as of early 2026

The 78-month gap between target-setting (2015) and operational strategy (2024) is itself analytically significant: it means the 50:50 target was a stated policy aspiration for nearly a decade without either a regulatory framework or an evidence base to translate it into planning decisions. During that decade Ballarat West PSP and Alfredton West PSP delivered the dominant share of housing, establishing the market patterns and development industry capacity that now make infill harder to shift.

Analysis

1. The Change Areas Framework — what it is, and what it is not

The Housing Framework Plan classifies all residential land into five categories. The first three apply to existing residential zones; the fourth applies to former industrial or underutilised sites identified for comprehensive redevelopment; the fifth is defined by the companion growth-areas-framework-plan and is outside the scope of this Strategy. (Source: housing-strategy-2041.txt §Change Areas)

Substantial Change Areas — Allow housing growth and diversity at increased densities. Applied to:

Areas that are very well-serviced by existing transport facilities (accessibility rating ≥70% per the Residential Accessibility Rating Analysis, Tract 2023);
Areas identified for urban renewal in the Ballarat Planning Scheme;
Underutilised industrial areas that have the potential to accommodate alternative uses, including housing, as identified in the Draft Industrial Land Strategy.

The planning objectives for Substantial Change Areas explicitly include “encourage the development of increased-density housing, particularly townhouses and apartments, to be defined through future structure planning” and “encourage a diversity of housing types, including smaller housing types (particularly one- and two-bedroom dwellings) and apartments with three or more bedrooms.” (Source: housing-strategy-2041.txt)

Incremental Change Areas — Allow modest housing growth while respecting existing character. Applied to residential land that is:

High-accessibility (≥70%) but within a Heritage Overlay (HO), Design and Development Overlay (DDO), or sensitive neighbourhood character context; OR
Not meeting the criteria for Substantial Change but not subject to the constraints that would warrant Minimal Change.

In practical terms this is the default classification — “residential land that is not either minimal or substantial change is identified as incremental change.” (Source: housing-strategy-2041.txt) Built form is anticipated to be “a mixture of future housing in the form of detached houses, dual occupancies, townhouses and apartments. New housing will generally be up to two storeys, consistent with the preferred neighbourhood character of the area.” (Source: housing-strategy-2041.txt)

Minimal Change Areas — Protect existing low-density residential character. Applied to areas:

Identified as bushfire landscape 3a (areas near forest hazards), 3b, or 4 (forest hazards) in the Strategic Planning for Bushfire in the City of Ballarat (Kevin Hazell Bushfire Planning, 2020);
Where the cost of providing services to support growth is prohibitive;
Identified for strategic reasons to maintain a compact form of urban development.

Built form is anticipated to be “predominantly comprised of one or two storey detached dwellings. Larger lots may be developed with more than two dwellings.” (Source: housing-strategy-2041.txt)

Urban Renewal Areas — Six sites identified with a combined theoretical yield of 8,643 dwellings at 35 dwellings per gross hectare, to be progressed through structure planning. (Source: housing-strategy-2041.txt, Table 11)

Growth Areas — Greenfield land governed by PSPs and the growth-areas-framework-plan, not within the scope of this Strategy.

Critical interpretation: The change areas framework as adopted is strategic intent, not a zone change. It is a layer above the existing residential zones (NRZ, GRZ, RGZ, LDRZ, TZ, MUZ) that will inform the forthcoming Residential Zones Review project. Until that review completes and a subsequent planning scheme amendment translates change areas into new zone schedules, the framework has no statutory force — individual permit applications in “Substantial Change” areas are still assessed under the existing GRZ or RGZ schedules. (Source: housing-strategy-2041.txt §Role of the Housing Strategy)

2. The accessibility rating methodology — mechanism and implications

The accessibility rating is the single most consequential technical input to the Change Areas framework. It is calculated via the Accessibility and Connectivity Analysis (Tract, 2023; referenced as Appendix 3 to the Strategy) and assesses the proximity of all areas in the City of Ballarat to ten destination types, each with a maximum walking catchment and a weighting. (Source: housing-strategy-2041.txt, Table 4)

Destination	Catchment	Weighting
Train stations	1,000m	100%
Bus stops	400m	33%
Retail	1,000m	66%
Supermarkets	1,000m	66%
Schools	1,000m	66%
Open space	1,000m	66%
Tertiary education	1,500m	66%
Community facilities	1,000m	33%
Health facilities	1,000m	66%
Essential services	1,000m	100%

An area qualifies for Substantial Change designation only where its cumulative accessibility rating reaches 70% or higher (absent a heritage or bushfire constraint).

Implications of the weighting. Train stations and essential services carry 100% weighting; bus stops and community facilities carry 33%. This means a property 300m from a premium railway station (Ballarat Central, Wendouree) gets a substantially higher score than a property 300m from a bus stop. The DTP raised an explicit submission on this during consultation — arguing that the weighting given to train stations implied service frequency and expansion commitments that were not in place, and sought assurance that increases in housing provision in accessible areas would be supported by increases in service frequency. (Source: housing-strategy-2041.txt §Urban Change Readiness Index / Infrastructure and Accessibility)

This submission is analytically significant because it identifies a conditional dependency: the accessibility rating methodology implicitly assumes that today’s train services will still be available (or will be augmented) at the scale that would support the density being directed to those catchments. If state rail service frequency is not augmented, the change areas framework may direct density to locations where transport service levels cannot sustain a substantially larger residential population, producing exactly the sprawl-by-default outcome the strategy aims to avoid.

Spatial implication. Map 7 (Overall Accessibility Rating, referenced as Figure 12 in the Strategy) shows highest accessibility in and close to the CBD and Wendouree Station Precinct. The Hospital Precinct, Sebastopol and Mount Clear Activity Centres also score high. Areas shown in red (low accessibility) are the suburbs furthest from transport, retail and services — most of which are also in Bush Residential character areas (Black Hill, Brown Hill, Mount Pleasant, Nerrina) where environmental and bushfire constraints separately trigger Minimal Change. (Source: housing-strategy-2041.txt; neighbourhood-character-study.txt §7.0)

3. The decision logic — a four-test sequence

Every parcel of residential land is classified through a four-test sequential logic (Source: housing-strategy-2041.txt, Figure 16):

Bushfire test. Is the area in a bushfire landscape 3a, 3b, or 4 per the Kevin Hazell Bushfire Planning report? If yes → Minimal Change.
Accessibility test. Is the accessibility rating ≥70%? If no → continue to test 4 for residual Incremental/Minimal allocation.
Heritage/character test (applied only if accessibility passes). Is the area in a Heritage Overlay or sensitive character area? If yes → Incremental Change. If no → test 3a. 3a. Urban renewal test. Is the area identified as an Urban Renewal Area? If yes → Substantial Change via structure plan. If no → Substantial Change under new residential zone.
Service sufficiency test (applied when accessibility <70%). Does the area have access to sufficient essential services and infrastructure that can support additional growth? If yes → Incremental Change. If no → Minimal Change.

Critical interpretation of the logic. The four tests have a specific ordering effect: bushfire trumps everything, heritage trumps accessibility (but doesn’t drop below incremental), and service sufficiency acts as a second-order filter for areas not quite meeting the accessibility threshold. The geography of “Substantial Change” is therefore the intersection of three positive conditions (accessibility ≥70%, not in HO, not in BMO/bushfire landscape 3-4) — a geography so constrained by Ballarat’s overlapping heritage and bushfire footprints that it reduces in practice to a handful of RGZ1 parcels near Wendouree Activity Centre and the Urban Renewal sites. RGZ1 land near the CBD is specifically downgraded to Incremental Change precisely because of the HO controls and sensitive character, confirming that heritage trumps accessibility even within the RGZ1 zone. (Source: housing-strategy-2041.txt)

4. The capacity assessment — established areas

The Tract Municipal Housing Capacity Assessment (2022, Appendix 4 to the Strategy) quantified the theoretical dwelling capacity of established areas under existing planning controls and then with change areas applied. (Source: ballarat-municipal-housing-capacity-assessment-tract-2022-extracted.txt; housing-strategy-2041.txt, Table 13)

Without change areas applied (under current controls only):

Established areas land supply: 30,261 additional dwellings
Zoned greenfield land supply: 16,200 dwellings
Total: 46,461 dwellings

With change areas applied:

Established areas land supply: 31,250 dwellings (up 989, or +3.3%)
Zoned greenfield land supply: 16,200 dwellings
Urban Renewal supply: 8,643 dwellings
Total: 57,093 dwellings

Analytical reading of the 989-dwelling increase. The modest increase when change areas are applied to established areas is the single most important finding in the capacity assessment. It confirms that the change areas framework is primarily a character-management and direction-of-growth tool, not a capacity-generation tool. Its value is in directing growth to accessible locations, not in increasing the total quantum of infill supply. The “substantial change” uplift in accessible areas is largely offset by the “minimal change” reduction in bushfire and low-accessibility areas where current GRZ rules theoretically permit more dwellings than the preferred character allows. (Source: ballarat-municipal-housing-capacity-assessment-tract-2022-extracted.txt)

Exclusions applied by Tract. The 30,261 and 31,250 figures are net of removing:

Public land uses
Strata-titled lots (body corporate consent required for redevelopment)
Individually significant heritage places
Recently developed properties
Parts of lots covered by existing or proposed Flood Overlay and Land Subject to Inundation Overlay
Parts of lots with trees ≥5m tall
Lots too small to accommodate a net additional dwelling under applicable density

Each exclusion is realistic but compounding. Strata-titled lots alone may exclude thousands of unit-complex sites from redevelopment potential in established suburbs. The 5m-tall-tree exclusion removes substantial areas of Ballarat’s treed inner-north suburbs from the theoretical capacity, even though individual trees could be managed through planning permit conditions. The HO exclusion of individually significant places is quite narrow (the HO generally applies to precincts; only a subset of properties within a precinct are “individually significant”), so most HO properties remain in the theoretical capacity — but they are harder to develop in practice because of the HO permit requirement for alteration.

Where the 30,261 capacity physically sits. The Strategy does not publish a sub-municipal breakdown of where within the LGA the 30,261 established-area capacity is concentrated. The Ballarat Infill Prioritization Framework (Astrolabe, 2024 — referenced but not in corpus) would detail the spatial distribution of established-area capacity. This is a CRITICAL gap for understanding where medium-density product can realistically absorb.

5. The three demand scenarios — land-sufficiency arithmetic

The Housing Needs Analysis (SGS, 2023, Appendix 2) forecasts three population-growth scenarios to 2041, and the Housing Strategy tests three dwelling-preference scenarios on top of the high-growth population case. (Source: ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt; housing-strategy-2041.txt)

Population growth scenarios (2021 base: 113,482):

Scenario	2041 population	Change	AAGR	Basis
Low	156,905	+43,423 (38%)	1.6%	VIF19 rebased to 2021 Census
Moderate	163,897	+50,415 (44%)	1.8%	Historical trends + Centre for Population
High	171,429	+57,947 (51%)	2.1%	Sustained peak COVID-era growth rate

The Strategy adopts the High Growth scenario because “projecting for population growth at the higher end of the scale allows for reduces the risk of decision makers under forecasting housing needs” — a deliberately risk-averse demand assumption. The resulting dwelling demand under High Growth is 28,961 additional dwellings by 2041 (50,204 to 79,165). (Source: housing-strategy-2041.txt, Table 5 and Table 7)

Dwelling demand by type under High Growth:

Type	2021	2041	Extra	% of extra
Separate house	42,262	65,087	22,825	78.8%
Attached dwelling	6,335	11,509	5,174	17.9%
Flat or apartment	1,409	2,332	923	3.2%
Other	198	237	39	0.1%
Total	50,204	79,165	28,961	100%

The demand is overwhelmingly for detached and attached dwellings. Flats and apartments account for just 3.2% of additional dwelling demand under the baseline typology preferences. This matters because the Wendouree Station (2,191 dwellings) and CBD (4,000 dwellings) urban renewal yields are almost entirely flats/apartments — which together represent 6,191 dwellings versus a projected 923-dwelling apartment demand over 20 years. The absorption risk is substantial, confirming the Strategy’s own observation that “the current limited market for apartment-style developments in the City of Ballarat, with only a few existing examples” is a material constraint. (Source: housing-strategy-2041.txt)

Infill share scenarios (applied to High Growth):

Scenario	Infill share	Greenfield demand (of 28,961)	Zoned greenfield supply	Years of greenfield supply
S1	20%	~23,170	16,200	18 years
S2 (Council policy)	50%	~14,480	16,200	22+ years
S3 (State aspiration)	70%	~8,690	16,200	37+ years

The 18-year figure for S1 is a narrow buffer above the 15-year minimum set under Clause 11.02-1S of the PPF, and it assumes complete and on-schedule build-out of Ballarat West PSP (8,800 lots), Alfredton West PSP (800 lots), and Northern Growth Areas Core Area (6,600 lots). Any slippage in Northern Growth Area delivery (which is pre-PSP) reduces this margin. (Source: housing-strategy-2041.txt, Tables 9–10)

The SGS Infill Uptake Analysis (2024, Appendix 5 to the Strategy) explicitly tested these three scenarios against the Tract capacity and concluded: “there is sufficient theoretical capacity to accommodate demand assuming a higher share of growth in infill locations, up to, and potentially exceeding the City of Ballarat’s policy aspiration for 50% of dwelling growth in infill areas.” (Source: housing-strategy-2041.txt, quoting Appendix 5) The corpus text for this Appendix is a duplicate of the main Housing Strategy PDF — the full standalone SGS analysis is a corpus gap.

Unzoned greenfield supply — the strategic reserve. Beyond the 16,200 currently-zoned greenfield dwellings, the Strategy identifies unzoned greenfield areas (Source: housing-strategy-2041.txt, Table 10):

Northern Growth Area (expanded area): 2,600 dwellings
Western Growth Area: 12,900–17,203 dwellings
North-Western Growth Area: 7,200–9,600 dwellings
Total unzoned greenfield: 22,700–29,403 dwellings

Adding unzoned to zoned gives 38,900–45,603 greenfield dwellings — more than adequate even under S1 (20% infill) for a 30+ year horizon. The strategic question therefore is not whether Ballarat has enough greenfield land; it is whether the sequencing of zoned and unzoned greenfield release can be managed to induce, rather than substitute for, infill uptake.

6. Urban renewal — the six sites, and what each actually is

The six urban renewal sites represent the largest single lever to shift the infill/greenfield balance. Their combined yield of 8,643 dwellings would account for approximately 30% of total dwelling demand under the high-growth scenario. (Source: housing-strategy-2041.txt, Table 11) Each is analysed below with the detail needed to evaluate deliverability.

6.1 CBD — 4,000 dwellings (theoretical)

Zoning and context. The CBD is predominantly Commercial 1 Zone (C1Z), which permits residential use. The area has some of the most intact and exceptionally high-quality heritage streetscapes in regional Victoria, with multiple Heritage Overlay precincts (HO168, HO172 and others). (Source: housing-strategy-2041.txt)

Yield assumption. 4,000 dwellings theoretical, with the Strategy explicitly anticipating heights “up to 8 storeys” in some areas. At typical apartment floor plate densities (approximately 150–200 dwellings per hectare gross for 6–8 storey development) the 4,000 figure implies approximately 20–27 hectares of redeveloped CBD land — a substantial intensification.

Binding constraints:

Heritage. “Varying degrees of heritage significance that require careful consideration in terms of future design responses.” (Source: housing-strategy-2041.txt) The Strategy specifically directs “Undertake urban design analysis and planning to determine an appropriate scale for future buildings across the various parts of the CBD, balancing heritage objectives.”
Flooding. “Some areas are prone to flooding, thereby limiting their development potential, or requiring considered design solutions for new buildings.” The Yarrowee River flows through the CBD and is one of the 11 waterways being assessed via the Ballarat 11 Waterways Flood Modelling (Water Technology, 2024). Implementation actions for the Housing Strategy include “Implement the 11 Waterways Flood Study and associated flood overlays into the Planning Scheme to ensure flood risk is considered in new development proposals.” (Source: housing-strategy-2041.txt §Implementation)
Interfaces with existing industrial land (Creswick Road).
Market absorption. The Strategy observes that apartment market demand is “currently limited” with only a few existing examples. At 28,961 projected dwellings to 2041 and a 3.2% apartment share (SGS baseline preferences), latent apartment demand is approximately 923 dwellings — less than a quarter of the CBD yield alone. Achieving 4,000 dwellings in the CBD requires either (a) a material shift in Ballarat’s housing preference distribution towards apartments, or (b) capture of non-local demand (students, retirees from surrounding shires, Melbourne downsizers).

Planning delivery path. The Strategy directs continued development of the Ballarat CBD Urban Design Framework and Structure Plan (Immediate / Short term timing, lead agency City of Ballarat Strategic Planning). Until this is in place, the 4,000-dwelling yield is indicative only. (Source: housing-strategy-2041.txt §Outcome 3)

Cross-reference. See ballarat-cbd-urban-design-framework and the Bakery Hill Urban Renewal Plan (October 2019, referenced in neighbourhood-character-study.txt §2.4) for related structure planning.

6.2 Wendouree Station Precinct — 2,191 dwellings

Zoning and context. 62.6 hectares comprising Industrial 1 Zone (IN1Z) and Industrial 3 Zone (IN3Z) land, located 4.8km from Ballarat CBD. Serves as a core industrial precinct hosting employment and population-servicing uses for north-west Ballarat and has direct access to train services extending to Melbourne and Ararat. Multiple lots of varying size, uses include industrial, warehousing, key logistics, manufacturing, commercial, and large-format retail. (Source: housing-strategy-2041.txt §Wendouree Station Precinct)

Existing planning scheme status. Already identified in the Ballarat Planning Scheme as:

An Urban Renewal Area – Wendouree Village (Clause 21.02-3 Urban renewal precincts);
An Ongoing Change Area (Clause 21.02-5);
A Major Activity Centre and Bulky Goods Centre in the Activity Centre Hierarchy;
A regional transport gateway.

The existing local policy (Clause 21.02-3) “seeks to facilitate redevelopment of the precinct.” The Wendouree Railway Station Masterplan was adopted in November 2022 and defines the Wendouree Station Precinct urban renewal area with proposed alternative land uses and public realm enhancements. The Masterplan is not yet implemented in the planning scheme and “revision is advised to ensure proposed actions are in line with current planning policy and direction.” (Source: housing-strategy-2041.txt)

Yield arithmetic. 2,191 dwellings across 62.6 ha gross gives 35 dw/ha gross — exactly matching the Strategy’s assumed 35 dw/ha urban renewal density. At typical mid-rise density (50–70 dw/ha) the yield could reach 3,100–4,400. The Strategy has therefore taken a conservative yield assumption. (Source: housing-strategy-2041.txt)

Binding constraints:

Existing long-term industrial and commercial uses with interfaces likely to persist over the long term. Many existing businesses continue to operate.
Noise from existing road and rail infrastructure. Development within the precinct will face amenity issues from the railway line itself.
Contamination potential. The Strategy directs application of an Environmental Audit Overlay (EAO) to all current industrial and commercial zones within each urban renewal area, in line with Ministerial Direction 1 – Potentially Contaminated Land. (Source: housing-strategy-2041.txt §Outcome 5, Action “Apply the Environmental Audit Overlay”)

Adjacent RGZ1 land. RGZ1 land located in proximity to Wendouree Activity Centre has been designated as “substantial growth” to reflect the opportunities this area has for producing compact neighbourhoods. This is distinct from the Urban Renewal Area itself and represents a separate uplift mechanism — medium-density development on RGZ1 land at existing zoning density caps (up to 4 storeys under RGZ1 schedule). (Source: housing-strategy-2041.txt)

Cross-reference. See wendouree-station-precinct-master-plan and the Activity Centre hierarchy under ballarat-activity-centres.

6.3 Latrobe Street Saleyards Precinct — 1,574 dwellings

Zoning and context. 343.6 hectares (the largest of the six sites by area), IN1Z with Development Plan Overlay 4 (undeveloped industrial land) in parts. Multiple sub-precincts: Latrobe Street, Northwest, Old Saleyards, Delacombe South West, and Alfredton South. Small-scale industrial sites plus large, open council-owned spaces including retail and hospitality. (Source: housing-strategy-2041.txt §Latrobe Street Saleyards Precinct)

Existing planning scheme status. Identified in the Ballarat Planning Scheme as Urban Renewal Area and ongoing change area, and as existing industrial — “protect from encroachment.” Planning policy for the site seeks to accommodate small-to-medium industrial needs through provision of lot sizes 1,500sqm–3ha in the Delacombe Industrial Area.

Yield arithmetic — the low yield per hectare is deliberate. 1,574 dwellings on 343.6 ha = 4.6 dw/ha gross — far below the 35 dw/ha urban renewal assumption. This is because “any residential change within this area is likely to include a limited portion of the site due to constraints which will be informed by future investigations and structure planning to detail suitable locations considering mitigation and buffers. This has been reflected in the limited anticipated yield for the area.” (Source: housing-strategy-2041.txt) The Strategy explicitly treats Latrobe Street as primarily an industrial retention precinct with surgical residential insertion, not a comprehensive redevelopment.

Binding constraints:

Areas of Aboriginal Cultural Heritage sensitivity partially affect the site, triggering Cultural Heritage Management Plan (CHMP) requirements under the Aboriginal Heritage Act 2006.
Existing long-term ongoing industrial and commercial uses creating poor sensitive-use interfaces.
Buffers resulting from industrial interfaces.
Noise from existing road infrastructure.
Existing contamination — remediation required before residential change.

Strategic opportunities:

Existing interfaces with residential land (on the residential side, opportunities for progressive transition);
Access and views to Victoria Park;
State commitment to remediate contaminated land on Old Saleyards site — an infrastructure dependency on state capital works (flag this as a cross-jurisdictional coordination item);
Use of old unused train line reaching the precinct from the north for transport access;
Existing successful creative retail and hospitality businesses indicating market change.

Planning delivery path. The Strategy directs “Prepare a Structure Plan for the wider Latrobe Street Saleyards Precinct to guide future land use and development.” This is a separate structure plan to the CBD and Wendouree Masterplans, and has not commenced.

6.4 Ballarat East / Eureka / Rodier Street — 836 dwellings

Zoning and context. 23.9 ha gross, comprising IN1Z and IN3Z parcels. Multiple lots with low-intensity industrial, general-purpose warehouse, manufacturing, and some detached dwellings. Some industrial uses generally support the local community. The Bushfire Management Overlay affects the southeastern portion of the precinct, and Areas of Cultural Heritage Sensitivity partially affect the site. (Source: housing-strategy-2041.txt §Ballarat East/Eureka and Rodier Street)

Yield arithmetic. 836 dwellings on 23.9 ha = 35 dw/ha gross — the standard assumption.

Binding constraints:

Existing long-term industrial and commercial uses creating long-term interface issues;
Potential for existing contamination (standard EAO trigger);
Smaller lot sizes and separate landowners — site assembly challenge;
BMO in the southeastern portion — directly constrains the developable area of the precinct.

Strategic opportunities. Location adjacent to Eureka Gardens and strong tourism focus. “City shaping opportunity maximising existing inner-city location and tourism focus.”

Planning delivery path. Structure plan required.

6.5 Lal Lal Street, Golden Point — 28 dwellings

Zoning and context. 0.8 ha, 15 Lal Lal Street, zoned IN3Z, Heritage Overlay HO172 (Creeks and River Channels Heritage Precinct) applies. Previously used as an industrial-scale bakery, unused for some time. Surrounded by low-density residential development (GRZ1). (Source: housing-strategy-2041.txt §15 Lal Lal Street)

Yield arithmetic. 28 dwellings on 0.8 ha = 35 dw/ha gross.

Binding constraints:

Small lot size (0.8 ha limits economies of scale);
Existing long-term ongoing industrial and commercial uses (nearby interfaces);
Potential for land contamination (former industrial bakery);
HO172 applies across the site, limiting demolition and external alteration.

Opportunities. Small number of landowners, very good accessibility to services, existing interface with residential GRZ1 (easier interface management).

Planning delivery path. “Rezone land to allow alternative land uses that are compatible with the surrounding residential context.” Requires a discrete rezoning amendment, with HO considerations.

6.6 Skipton Street, Ballarat Central — 14 dwellings

Zoning and context. 313 Skipton Street (north-east, sheet metal manufacturing) zoned IN1Z with HO168 (South Ballarat Heritage Precinct) applying; 317 Skipton Street (south, automotive repairs) zoned IN3Z with Areas of Cultural Heritage Sensitivity partially affecting the site. 0.4 ha total. Close to Ballarat CBD with good connectivity to the Midland Highway. (Source: housing-strategy-2041.txt §313 and 317 Skipton Street)

Yield arithmetic. 14 dwellings on 0.4 ha = 35 dw/ha gross.

Binding constraints:

Existing long-term ongoing industrial and commercial uses (neighbour effect during transition);
Potential contamination (automotive repairs and sheet metal);
HO168 applies (South Ballarat Heritage Precinct).

Opportunities. Very good accessibility, proximity to CBD and Midland Highway.

Analytical note on the small sites. Lal Lal Street (28 dwellings) and Skipton Street (14 dwellings) together yield just 42 dwellings — 0.5% of the total urban renewal supply. They are retained in the Strategy because they demonstrate the urban renewal principle at small scale (converting redundant industrial premises to residential in inner locations), but their material contribution to the 50:50 target is immaterial. Their value is strategic signalling, not dwelling delivery.

6.7 Sites considered and excluded

Selkirk Precinct (including 630 Howitt Street, Ballarat North; 804–810 Norman Street, Invermay; 735 Creswick Road, Wendouree). The Ballarat Planning Scheme identifies Selkirk as an urban renewal area, but the Housing Strategy has excluded it following consultation with owners, who “have indicated an ongoing commitment and investment in industrial uses into the medium-long term.” (Source: housing-strategy-2041.txt §Opportunities) This is a critical analytical point: landowner cooperation is a prerequisite for urban renewal conversion, and the Strategy has accepted owner intent as binding here — a reasonable position, but one that means Selkirk’s renewal capacity is foregone for the planning horizon.

Draft Industrial Land Strategy sites. The Draft ILS (City of Ballarat, 2024) identifies additional sites with residential potential: Skipton Street; Lal Lal Street; the Ballarat East Precinct (Eureka/Stawell/Charlesworth/Fussell Streets); and Rodier Street. These align with the sites incorporated into the Housing Framework, though the Housing Strategy includes the Ballarat East Precinct and Rodier Street as a combined site.

6.8 Urban renewal prioritisation framework — the Astrolabe work

The six Urban Renewal Areas will be prioritised using a multi-criteria analysis (MCA) framework developed by the Ballarat Infill Prioritization Framework (Astrolabe, 2024), which uses principles drawn from Infrastructure Australia’s 2021 Guide to Multi-Criteria Analysis. The four stated principles are:

Match the tool to the task — the framework complements Council’s existing processes;
Be transparent — documentation must enable understanding of MCA logic and design;
Address relevant assessment criteria — criteria must be sufficiently met for robust decisions;
Address deliverability — prioritisation must have regard to financial and time considerations, including supply-side constraints.

The inputs required for each site (Source: housing-strategy-2041.txt, Table 12):

Consideration	Requirements	Source
Water infrastructure	Pipe capacity, treatment capacity, equivalent tenements	Central Highlands Water
Stormwater	Infrastructure and capacity	CMA, City of Ballarat
Sewerage	Infrastructure and capacity	Central Highlands Water
Energy	Existing and planned infrastructure	Powercor (elec), AusNet (gas)
Telecommunications	Internet speed, type, connections	NBN, Telstra
Open space	Audit	City of Ballarat
Flooding	Flood prone land	City of Ballarat, CMA
Contamination	Site audits, remediation plans	City of Ballarat, landowners
Planning objectives	Scheme overlays, zones, current use, strategic directions	City of Ballarat, State
Employment	Existing employment numbers	City of Ballarat, landowners
Accessibility	Accessibility mapping	City of Ballarat
Government infrastructure	Existing and planned	State Government
Developer attraction	Projects, permits, feedback, feasibility	City of Ballarat, landowners

The Housing Strategy commits to applying the framework to all six sites in the order:

Skipton Street
Lal Lal Street
Ballarat East
Rodier Street
Wendouree Station Precinct
Latrobe St Saleyards Precinct

Interpretation. The ordered list appears to be the sequence of assessment, not necessarily the sequence of delivery. The Astrolabe Framework itself is not in the corpus — a CRITICAL gap, since it would contain the specific rankings, weightings, and the public-finance requirement estimate that drives delivery sequencing. The sequence listed suggests simple-first, complex-last — starting with small sites (Skipton, Lal Lal) to establish process before tackling Latrobe Street (343.6 ha, state remediation dependency, industrial retention tension).

7. Why infill is declining — the five structural causes

Between 2019 and 2024, infill’s share of building permits fell from 40% to 30%, averaging 30% across the five-year series. (Source: housing-strategy-2041.txt, Table 8) Despite being an explicit policy target for nine years at the start of the series, the revealed trend moved further from the target, not closer to it.

Year	Total dwellings	Greenfield	Infill	Split
2019	1,017	610	407	60/40
2020	1,715	1,162	553	68/32
2021	2,013	1,426	587	71/29
2022	1,570	1,210	360	77/23
2023	1,087	775	312	71/29
2024 (Jan–Apr)	339	230	109	68/32
Total	7,741	5,413	2,379	70/30

Five structural factors explain this trajectory (Source: housing-strategy-2041.txt; ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt):

Cause 1: Abundant and cheap greenfield supply. Ballarat West PSP provides approximately 8,800 lots at 15 lots/ha with full infrastructure, DCP-funded enabling works, and a well-established development industry. The path of least resistance for builders and buyers is a new house on a new lot. Alfredton West adds 800 lots and the Northern Growth Areas Core Area 6,600. Cumulative zoned greenfield supply of 16,200 provides 22+ years of supply even at 50:50.

Cause 2: Infill is harder to deliver. Medium-density development in established areas faces:

Heritage constraints (12,000+ properties in HO);
Neighbourhood opposition evidenced through the VCAT cases summarised at §11 below;
Complex site assembly (older lots are individually titled, often with different owners — consolidation is time-consuming and expensive);
Uncertain planning outcomes — until new residential zones are applied, permit decisions are made under existing GRZ/RGZ/NRZ schedules that were not calibrated to the Change Areas framework.

The SGS survey found only 8% of movers would seek medium/high-density housing, while 79% preferred 3+ bedroom dwellings — a revealed-preference mismatch between what the Strategy would deliver and what buyers say they want. (Source: ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt §Housing Preferences Survey)

Cause 3: Planning controls have not been updated. The residential zones review — the mechanism for translating the Change Areas framework into binding zone schedules — has not commenced as of early 2026. Without zone changes, the Change Areas framework is strategic intent, not regulatory reality. A permit applicant in a “Substantial Change” area in 2026 is still assessed under the existing GRZ schedule, not the forthcoming substantial-change schedule.

Cause 4: No infrastructure incentive. Established areas are described as “generally well serviced” (Source: housing-strategy-2041.txt), but there is no targeted infrastructure investment program to make specific infill locations more attractive. The Housing Strategy identifies the need to “develop funded Infrastructure Plans to support housing growth” as a “Short term” action (Outcome 2). The funded plans are not in place, meaning that even where capacity theoretically exists, there is no signal to developers about where infrastructure investment will concentrate. By contrast, in greenfield areas the DCPs explicitly monetise infrastructure delivery and give developers a fixed $/ha NDA cost to build into project feasibility.

Cause 5: COVID-era demand favoured greenfield. The pandemic triggered demand for larger homes with yards and larger lots, favouring greenfield over infill. Building permits peaked at 2,013 in 2021, with greenfield capturing 71% — the highest share. The 2022 peak in greenfield share (77/23) reflects the sustained effect of pandemic-era preferences plus timing lags in approvals. The 2024 data (68/32) shows modest reversion, but well short of the target.

8. The heritage constraint — 12,000+ properties

Ballarat has over 12,000 properties in the Heritage Overlay — one of the largest heritage-protected property portfolios of any municipality in Victoria outside of central Melbourne. Most are concentrated in the CBD and surrounding residential suburbs, with smaller concentrations in Buninyong and Learmonth. (Source: housing-strategy-2041.txt §Heritage)

Areas of particular cultural heritage sensitivity include (Source: housing-strategy-2041.txt):

Bridge Mall, Bakery Hill, Main Road, Humffray Street (Ballarat East civic/commercial heritage);
Parts of Soldier’s Hill, Ballarat Central and Lake Wendouree (exceptionally high-quality heritage precincts);
Ballarat East, Newington and Lake Wendouree (highly intact subdivision patterns).

The change areas framework classifies heritage-overlaid areas with high accessibility as “Incremental Change” rather than “Substantial Change”. This means the areas closest to train stations, activity centres, and services — the most logical locations for infill intensification — are precisely the areas most constrained by heritage protection. This is not a flaw in the framework; it reflects a genuine tension between housing intensification and heritage conservation that is central to Ballarat’s identity as a goldfields city. But it limits the practical geography available for substantial infill, concentrating the infill burden on non-heritage areas that may be further from services or on the six urban renewal sites.

The Heritage Gaps Analysis currently being undertaken by the City of Ballarat will identify further places and precincts of potential heritage significance. Its outcome is potentially capacity-reducing — the 30,261 theoretical capacity from Tract excludes “individually significant heritage places” at the time of the study; any new individually significant listings from the Gaps Analysis further erode it.

VCAT pattern on HO. One of the five VCAT cases reviewed (Liu v Ballarat CC [2020] VCAT 756) specifically tested higher-density development within the Convenience Living Corridor in a GRZ1 that was also subject to HO166. VCAT’s treatment of these hybrid cases is a recurring issue: previous appeals have cited “the lack of metrics to exercise discretion in applications within a Heritage Overlay that achieve policy objectives.” VCAT “was not satisfied that the proposal would achieve acceptable heritage and character outcomes.” (Source: neighbourhood-character-study.txt §5.1) The practical consequence is that even in RGZ1-zoned land inside the Convenience Living Corridor, HO controls dominate outcomes — reinforcing the Strategy’s decision to classify RGZ1-near-CBD as Incremental Change rather than Substantial Change.

9. Neighbourhood Character Study — the binding parallel framework

The neighbourhood-character-study (Ethos Urban, August 2024) is the companion document to the Housing Strategy. Together they form the Residential Development Framework required by PPN90. The NCS identifies six Neighbourhood Character Types with sub-types across the municipality (Source: neighbourhood-character-study.txt §7.0):

Bush Residential (sub-types BR1, BR2) — low-density development on the edge of or within bushland. BR1: sloping land, informal curvilinear streets, unsealed roads, 5–10m setbacks, 650–1,900 sqm lots, 10–50% site coverage, predominantly single storey. BR2: undulating topography, sealed roads, 3–10m setbacks, 700–1,000 sqm lots, 20–50% site coverage.
Garden Court (GC1, GC2) — late 20th century estate typology, grid and curvilinear street networks with court bowls, low vegetation, absence/low fencing.
Garden Residential — the dominant inter-war/post-war established suburban typology with tree-lined streets, single to double storey, formal/informal gardens.
Lakeside Garden — around Lake Wendouree, mix of single, double and three storey, built form maximising views, minimal to general setbacks, minimal side setbacks.
Rural Residential — large lots, generous setbacks, views to surrounding farmland.
Urban Core (UC1, UC2) — inner-city heritage typology, mix of Victorian/Edwardian/Interwar/Post-war, minimal to typical front setbacks, minimal side setbacks, predominantly weatherboard and brick.

Each character type has a Preferred Character Statement and Design Guidelines which will be implemented through schedules to residential zones as part of the Residential Zones Review. For Bush Residential 1 the Incremental Change setback requirement is “minimum 2m from one side” and “setback upper levels above 2 storeys to achieve visual recession” — materially more permissive than the 3m Minimal Change side setback, yet still more constrained than a generic GRZ variable setback. For Bush Residential 1 in Incremental Change, the indigenous canopy tree density requirement is one per 150 sqm (vs one per 100 sqm in Minimal Change). (Source: neighbourhood-character-study.txt §8.3 Design Guidelines)

Permeability and site coverage controls. Bush Residential 1 design guidelines cap site coverage at 40% and require at least 40% permeable surface. These are materially more restrictive than the default ResCode standards and will bind medium-density product in Bush Residential areas — a structural reason why BR areas (and much of Ballarat’s fringe established-area land) are inherently not suited to townhouses or apartments. (Source: neighbourhood-character-study.txt §8.3 Design Guidelines)

Character study’s treatment of Change Areas overlap. “For each character area, objective 5 will be replaced with an additional objective when referring to new development located in the areas identified for Incremental and Substantial Change.” (Source: neighbourhood-character-study.txt §8.2) The NCS therefore implements the Change Areas framework in the character schedule, not as a parallel but as an integrated layer. For an applicant in an Incremental Change area within Bush Residential 1, the applicable design objective is the Incremental-specific objective 5 replacing the default objective 5.

DTP submission on NCS. The DTP’s Stage 2 submission asked for:

The preferred neighbourhood character should be considered separately from level of change, rather than defining preferred character based on the level of change envisaged for an area;
Geographical boundaries of each character area should be mapped to avoid misalignment with change areas;
Character areas should be consolidated so one housing change area maps to one character area;
Recommendation for a Residential Development Framework map to show both. (Source: neighbourhood-character-study.txt §3.2)

The Strategy has largely complied with these requests by integrating the two frameworks, though the boundary alignment issue persists: some character areas span multiple change area classifications and will require discretion at the permit level.

10. Environmental and hazard constraints — the non-heritage capacity filters

Beyond HO, five additional overlay layers constrain infill delivery:

Bushfire Management Overlay (BMO). Under the Ballarat Strategic Planning for Bushfire (Kevin Hazell Bushfire Planning, 2020), land classified as bushfire landscape 3a, 3b, or 4 is automatically Minimal Change in the Change Areas framework. The BMO extends across much of the eastern and south-eastern fringe, particularly Brown Hill, Canadian, Mount Helen and parts of Ballarat East. Additionally, under Clause 52.12 (Bushfire Protection: Exemptions), vegetation within 10m of a dwelling used for accommodation may be cleared (for buildings constructed before September 2009 within a Designated Bushfire Prone Area), and vegetation within 50m (in BMO land) — “regardless of whether a permit is required to remove vegetation under any other provision of the planning scheme.” (Source: neighbourhood-character-study.txt §5.2) This exemption trumps VPO, ESO, and Cl 52.17 Native Vegetation triggers — meaning vegetation removal occurs at the property owner’s discretion in BMO land, with cumulative impact on the “treed” character of Ballarat. The Housing Strategy does not quantify how many of the 30,261 established-area theoretical dwellings are in BMO land; given the large spatial footprint of the eastern BMO extent, this is likely to be a material reducer of realisable infill capacity.

Flood Overlay (FO) and Land Subject to Inundation Overlay (LSIO). Parts of lots covered by existing or proposed FO/LSIO are excluded from the theoretical capacity assessment by Tract. The Ballarat 11 Waterways Flood Modelling (Water Technology, 2024) is assessing 11 waterways including the Yarrowee River through the Ballarat CBD; implementation of the resulting flood overlays into the planning scheme is an Immediate Strategy action. The scope and extent of new FO/LSIO application is not yet known — it is potentially capacity-reducing across the Yarrowee corridor, which cuts through Ballarat North, Ballarat Central, Ballarat East, Redan, Sebastopol, and Delacombe. (Source: housing-strategy-2041.txt §Outcome 5)

Environmental Audit Overlay (EAO). The Strategy commits to applying EAO to all current industrial and commercial zones within urban renewal areas before residential use — implementing Ministerial Direction 1 (Potentially Contaminated Land). This adds a site-audit cost ( $25,000-$ 150,000 typical) and timeline (6–18 months for remediation where needed) to urban renewal delivery. (Source: housing-strategy-2041.txt §Outcome 5)

Vegetation Protection Overlay (VPO) and Environmental Significance Overlay (ESO). The Strategy observes that “the Ballarat Planning Scheme not currently providing sufficiently robust planning controls to ensure identified and non-identified environmental values are protected” and recommends “an urgent and essential need to review the Vegetation Protection Overlay and the Environmental Significance Overlay.” (Source: housing-strategy-2041.txt §Environmental Sustainability and Biodiversity) ESO5 (Koala Habitat) restricts development in identified koala habitat areas — a material constraint across parts of Brown Hill, Nerrina and Canadian.

Airport Environs Overlay (AEO). Applied to land subject to elevated aircraft noise and restricts sensitive land uses. Ballarat Airport is in the north-west; the AEO footprint constrains parts of Mitchell Park and the approach corridors.

11. VCAT cases — the enforcement pattern

Five VCAT cases reviewed by the NCS illuminate how the existing planning scheme handles infill and density tension (Source: neighbourhood-character-study.txt §5.1):

Monsien Holdings Pty Ltd v Ballarat CC [2019] VCAT 324 — Tested higher-density development within the Convenience Living Corridor in GRZ1. Relevant to whether the GRZ1 within a Convenience Living Corridor supports substantial density uplift.

Liu v Ballarat CC [2020] VCAT 756 — Higher-density development in GRZ1 + HO166. VCAT “was not satisfied that the proposal would achieve acceptable heritage and character outcomes.” Reinforces that HO controls dominate in hybrid GRZ1/HO cases.

New Home Shop Pty Ltd v Ballarat CC [2024] VCAT 313 — Subdivision within NRZ1, subject to ESO5, BMO and VPO1, plus the Canadian Valley Outline Development Plan. VCAT “reaffirmed City of Ballarat refusal to grant a permit on the grounds that the proposed subdivision did not adequately respond to the requirements of the ESO5, BMO and VPO1.” Demonstrates that overlapping overlays are generally upheld by VCAT against intensification proposals.

Howlett v Ballarat CC [2023] VCAT 340 — Higher-density development within the RGZ. City of Ballarat issued a Notice of Decision to grant a permit following objections; VCAT supported Council’s decision. Demonstrates RGZ density uplift can be defended where it aligns with the zone purpose.

Pilmore v Ballarat CC [2023] VCAT 568 — Three-lot subdivision in an Ongoing change area and within the Canadian Valley Outline Development Plan. VCAT “was satisfied that the proposals were consistent with the local policies and strategic directions and balanced the existing and preferred outcome for the sites. The role of Clause 71.02-3 in balancing conflicting objectives was highlighted.”

Pattern implications:

Where overlays dominate (HO, ESO, BMO, VPO), density proposals fail at VCAT (Liu, New Home Shop).
Where the zone purpose aligns with density (RGZ) and the area is not in an overlay, density proposals succeed (Howlett).
Where Ongoing change and policy direction supports progressive subdivision, modest density is upheld (Pilmore).

Gaps in the scheme identified by VCAT:

Lack of specific Neighbourhood Character Objectives and guidelines in residential zone schedules;
Lack of character and built form guidance when exercising discretion in applications under an HO;
Lack of guidance in local policy that informs preferred character outcomes.

The NCS and its forthcoming zone schedule translations directly address all three gaps. Until the Residential Zones Review completes and zone schedules are amended, these gaps persist in the planning scheme — meaning current applications cannot be assessed against the framework the Strategy sets up.

12. State policy integration — the Housing Statement and its three amendments

Three amendments arising from Victoria’s Housing Statement (September 2023) interact with the Ballarat framework:

Amendment VC242 (gazetted 20 September 2023) introduced two new controls:

Clause 53.22 — Significant Economic Development. Facilitated assessment pathway for significant economic development.
Clause 53.23 — Significant Residential Development with Affordable Housing. Facilitated pathway for residential proposals that include affordable housing; the Minister for Planning is the Responsible Authority, bypassing Council decision-making. Voluntary; does not apply to live applications. (Source: housing-strategy-2041.txt §State Housing Policy; neighbourhood-character-study.txt §2.3)

Amendment VC243 (gazetted 20 September 2023) delivered three changes:

Codification of residential development standards at Clauses 54 (one dwelling) and 55 (two or more dwellings).
Future Homes (Clause 53.24) — three-storey apartment designs adapted across GRZ provided within 800m of a railway station or identified activity centre, and not in HO or NCO. Approved exemplar designs by DTP.
Removal of the permit requirement for a single dwelling on a lot ≥300 sqm in GRZ, NRZ and TZ. The provision that previously mandated a permit for constructing/extending a single dwelling (or fence within 3m of a street) on such lots is removed. This is significant because it strips Council of the permit trigger that previously could have conditioned single dwelling design outcomes against neighbourhood character — except where an overlay applies.
VicSmart pathway for single dwellings on lots <300 sqm — reducing administrative cost.

Amendment VC253 made changes coordinating approval processes for small second homes (“granny flats”) up to 60 sqm. A small second home no longer requires a planning permit in most cases where there is no flooding, environmental or other special planning controls. Cannot be subdivided or separately sold. (Source: neighbourhood-character-study.txt §2.3)

Implications for the Change Areas framework.

The permit exemption for single dwellings on ≥300 sqm lots is consequential in Incremental Change areas in the GRZ. Council can no longer condition single-dwelling design outcomes against the NCS preferred character statements through the permit process, except where an HO or NCO applies. This is a material weakening of the character-protection mechanism precisely in the incremental-change geography where the NCS was intended to bind design outcomes. Outside of HO-covered areas (which become Incremental by the Logic test), single dwellings are effectively exempt from character conditioning.
Future Homes (Cl 53.24) operates only in GRZ within 800m of a station or activity centre, not in HO or NCO. This is a narrow geography in Ballarat — essentially the Wendouree and CBD station catchments excluding HO-covered parts. Most of those catchments are in HO. The Strategy observes that state-level mechanisms “may incrementally increase infill uptake without requiring council action, but their impact in a regional city with lower land values and weaker medium-density demand than metropolitan Melbourne is uncertain.” (Source: housing-strategy-2041.txt) The conservative reading is that Future Homes will produce a handful of apartment developments per year in Ballarat, not a step-change.
Clauses 53.22 and 53.23 allow the Minister to become Responsible Authority on significant residential development with affordable housing. This is potentially consequential for the Urban Renewal Areas — a developer could propose a large CBD or Wendouree Station development under Cl 53.23 and bypass Council. Whether Council supports or resists this depends on case-by-case alignment with the Change Areas framework.

13. Affordable housing — the layered framework

The affordable housing treatment in the Strategy is layered across four documents:

Ballarat Affordable Housing Position Statement (August 2022) — Establishes Council’s role as “shared” (one of many responsible stakeholders) with four functions: Planner/Regulator, Advocate, Educator, Facilitator. Recognises the Planning and Environment Act 1987 definition of affordable housing (Section 3AA) as housing appropriate for very low, low, and moderate income households. For regional Victoria (including Ballarat), the income brackets are: single adult up to $44,100; couple no dependents up to$ 66,160; family up to $92,610. References the June 2018 amendment to the P&E Act that added objective “to facilitate the provision of affordable housing in Victoria” — removing a hurdle for Responsible Authorities seeking to facilitate affordable housing. (Source: affordable-housing-position-statement-final-2022.txt)

Diverse and Affordable Housing Discussion Paper (2023) — not in corpus; referenced.

Draft Social and Affordable Housing Action Plan (2024) — Three tiers of influence:

Tier 1: Facilitating efficient housing markets. Partnerships, education, relationship building with industry.
Tier 2: Facilitating affordable housing supply. Strong advocacy position backed by articulated policy and strategy.
Tier 3: Investing in affordable housing as a direct agent of supply. Ratepayer funds and assets (such as land) deployed to this end.

Five principles govern implementation (Source: housing-strategy-2041.txt §Affordable Housing):

Support affordable housing in areas with good access to schools, shops, services, open space, and public transport.
Support and advocate for increased investment in diverse and affordable housing that is high quality, accessible, sustainable and climate resistant.
Encourage and advocate for support services to ensure successful housing outcomes.
Encourage and advocate for mixed tenure developments.
Organisation-wide approach to align affordable housing actions with other strategies.

Housing Strategy 2041 treatment. The Strategy commits to:

Development of evaluation criteria about site suitability for social and affordable housing (location, proximity to services, transport, cost);
Audit of City of Ballarat and State Government land and assets against these criteria;
Rating of all identified sites from most feasible to least feasible;
Identification of delivery models (Council as advocate / supporter / investor / partner);
Ongoing consultation with the development community to increase awareness of the housing crisis and make provision for social and affordable housing within subdivisions, assisting with State and Federal investment opportunities.

The Strategy specifically considers “inclusionary zoning in a greenfield or urban renewal context” as an ongoing action — a mechanism-level signal that inclusionary zoning is under consideration but not yet implemented. (Source: housing-strategy-2041.txt)

Cross-reference to the Ballarat North PSP Affordable Housing Needs Assessment (VPA, July 2025) — see ballarat-north-psp. The VPA assessment sets quantified affordable housing targets for the North PSP growth area; the infill Strategy does not set numeric targets. This asymmetry is analytically important: greenfield development in Ballarat is progressively being required to deliver quantified affordable housing, but infill is not. All else equal, this subsidy gradient tilts developer behaviour towards greenfield relative to infill — a counter-incentive to the 50:50 target.

14. The dwelling typology mismatch

The Ballarat housing stock has a structural mismatch between dwelling size and household size (Source: housing-strategy-2041.txt §Housing Needs; ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt):

2021 household composition:

Lone person: 29.5% (largest share)
Couple without children: 24.9%
Couple with children: ~24.7%
Group/multi-family/other: ~20.9%

2021 dwelling size:

3-bedroom: 47.8% (largest share)
4-bedroom: 28.8%
2-bedroom: 16.0%
1-bedroom: 3.4%
5+ bedroom: 3.8%

Only 20% of dwellings have fewer than three bedrooms, while 54% of households are lone person or couple-without-children. Average persons-per-household is 2.26 in 2021, projected to decline to 2.00 by 2041. The HNA’s demand forecasts project that 21% of new dwellings under the 50:50 aspirational scenario (S3) should be 2 bedrooms or less — a material shift from historical patterns.

Implication for the Change Areas framework. The Substantial Change Areas and Urban Renewal Areas are exactly where smaller dwellings (1-bedroom and 2-bedroom apartments/townhouses) are intended to be delivered. The Strategy’s implementation includes “Provide housing diversity in new development including the provision of 1, 2 and 3 bedroom apartments and townhouses for 10 or more dwellings” as an ongoing action. (Source: housing-strategy-2041.txt §Outcome 3)

Risk. The SGS Housing Preferences Survey found 79% of moving households preferred 3+ bedrooms and only 21% preferred 1–2 bedrooms — implying the current preference mix is 79/21, while the S3 (50:50) scenario requires only 52% 4+ bedroom, 27% 3 bedroom, and 21% ≤2 bedroom. A material shift in preferences is required, and preference shifts are slow. The Strategy implicitly assumes that the dwelling-typology preferences will shift to match what the Change Areas framework delivers — a demand-induced-by-supply assumption that is not guaranteed.

15. The infrastructure dependency — why infill is contingent on capital works

The Strategy asserts that established areas are “generally well serviced” (a 2014 infrastructure assessment confirmed basic provision across wastewater, drainage, electricity, gas, potable water, and telecommunications), but recognises that augmentation and extension of key sites is required to increase capacity. Three infrastructure dependencies are specifically flagged:

Central Highlands Water (CHW). Pipe capacity, treatment capacity, equivalent tenements all assessed per Urban Renewal Area. The Wendouree Station Precinct (2,191 dwellings), Latrobe Street Precinct (1,574 dwellings), and Ballarat East (836 dwellings) are in the dense industrial parts of the network where the sewerage augmentation requirements will be material. The Strategy does not quantify the $ or timing required. Reference CHW’s capital works programs — this is a cross-jurisdictional dependency that the Strategy formally acknowledges but has not mapped.

Powercor (electricity) and AusNet (gas). Energy infrastructure, existing and planned, forms a prioritisation input. The CBD (4,000 dwellings) in particular will require major electrical capacity augmentation for apartment developments with lifts, commercial ground floors, and EV charging.

VicRoads/DTP transport. The Strategy commits to “Develop an Integrated Transport Strategy for Ballarat to ensure efficient provision of transport infrastructure” (Short term, Outcome 2) as a response to housing growth. The Integrated Transport Strategy is referenced as currently being updated in line with Housing Strategy findings. The existing Draft Ballarat Integrated Transport Action Plan (2020) predates the Housing Strategy and requires re-calibration. (Source: housing-strategy-2041.txt §Local Policy)

The binding constraint. Until CHW sewer augmentation capacity in the CBD and Wendouree Station is costed and programmed, and until the Integrated Transport Strategy is finalised with specific upgrades tied to the Change Areas framework, the urban renewal yield is indicative only. The 8,643 urban renewal dwelling capacity is notional pending these capital works programs. This is analytically identical to the position in greenfield areas, where PSP yields are contingent on DCP-funded infrastructure — but the mechanism for funding infill infrastructure (rates, grants, or developer contributions via Section 173 agreements) is less developed than the DCP mechanism that funds greenfield infrastructure.

16. The implementation sequence — what must happen and when

The Strategy’s implementation plan identifies 14 actions across five outcomes, with timings ranging from Immediate to Long term. (Source: housing-strategy-2041.txt §Implementation Plan) The actions directly relevant to infill delivery:

#	Action	Outcome	Lead	Timing	Status (early 2026)
1	Planning scheme amendment to implement Housing Strategy and Housing Framework Plan	1	City of Ballarat / Minister	Immediate	Not commenced
2	Implement Growth Areas Framework Plan into Planning Scheme	1	City of Ballarat / Minister	Immediate	Not commenced
3	Facilitate infill through new residential planning controls and structure planning in Urban Renewal Areas	1	City of Ballarat / Minister, community, relevant authorities	Immediate	Not commenced
4	Monitor population growth and housing supply (VIF, UDP)	1	City of Ballarat	Medium term / Ongoing	Ongoing (building permit data collected)
5	Implement Housing Framework Plan into Planning Scheme to identify locations for higher density	2	City of Ballarat / Minister	Immediate	Not commenced
6	Develop Integrated Transport Strategy	2	City of Ballarat Strategic Planning	Short term	Not commenced
7	Undertake prioritisation of Urban Renewal Areas (Astrolabe MCA)	2	City of Ballarat	Short term	In progress (Astrolabe framework exists; rankings not published)
8	Develop funded Infrastructure Plans	2	City of Ballarat + State + Minister	Short term	Not commenced
9	Review residential zones and overlays to align with Housing Framework Plan	3	City of Ballarat / Minister	Immediate	Not commenced
10	Develop precinct plans for urban renewal areas	3	City of Ballarat / Minister / community / agencies	Short term	Not commenced
11	Continue to develop the Ballarat CBD Urban Design Framework and Structure Plan	3	City of Ballarat	Immediate / Short term	In progress
12	Progress Diverse and Affordable Housing Strategy	3	City of Ballarat	Immediate / Short term	Draft 2024 published
13	Develop new residential planning controls consistent with Neighbourhood Character Study	4	City of Ballarat	Immediate / Short term	Not commenced
14	Apply EAO to Urban Renewal Areas within Industrial Zone	5	City of Ballarat / Minister / EPA	Short term	Not commenced
15	Implement 11 Waterways Flood Study and associated flood overlays	5	City of Ballarat / Corangamite CMA / Minister	Immediate	Not commenced

Critical path. The sequence that must happen for any Urban Renewal dwelling to be delivered:

Planning scheme amendment to implement the Housing Strategy (Immediate — 6–12 months typical) →
Residential zones review (Immediate — 12–18 months) →
Second planning scheme amendment to implement new zones (Short term — 6–12 months) →
Structure plan for specific Urban Renewal Area (Short term — 12–24 months per site) →
Rezoning within structure plan (Short term — 6–12 months) →
EAO application and site audits (Short term — 6–18 months per site) →
Permit applications → construction → occupation.

Total critical path time: 4–7 years minimum from adoption (August 2024) to first urban renewal occupation. This places first urban renewal dwelling occupation in the 2028–2031 window — consistent with the Strategy’s expectation that “from 2031 onwards infill will become the dominant form of development.” (Source: housing-strategy-2041.txt §Location of Housing)

Critical gap: As of early 2026 (18 months after adoption), none of the six “Immediate” actions have commenced. Any slippage beyond Q2 2026 risks pushing the critical path past 2031, which would in turn mean infill does not become dominant within the Strategy’s 15-year horizon.

17. Submission analysis — who said what

The Strategy received submissions across three engagement stages. The Stage 2 consultation (August–October 2023) received 76 written submissions (Source: neighbourhood-character-study.txt §3.2):

23 from community members;
27 from the development industry;
8 from consultants on behalf of landowners;
11 from agencies and government departments;
7 from community groups.

Thematic analysis of submissions:

On the 50:50 target itself:

Survey respondents in 2021 Discussion Paper consultation: 29.1% supported 70/30 infill (highest cohort), 19.4% supported 50/50, remainder split across lower infill shares. (Source: housing-strategy-2041.txt §Key Engagement Findings)
The majority of written submissions argued that infill development in Ballarat was “undesirable or unachievable for a range of different reasons” — referencing an earlier report identifying challenges in the delivery of infill via traditional property market mechanisms. Submissions sought adjustment of the target to support increased greenfield development, with some seeking additional rezonings. This position was largely from the development industry.
Submissions supporting 50:50 or higher infill target highlighted: financial costs to council and community in continued urban sprawl; biodiversity impacts; agricultural and landscape values; climate change.
The VPA confirmed that there is sufficient greenfield supply for almost 20 years, indicating sufficient capacity within the growth areas alone to provide for identified growth — a position that implicitly supports deprioritising infill if infill is hard to achieve.

On infrastructure and accessibility:

DTP raised concerns about the weighting given to train stations, arguing that increased housing provision in accessible areas needed to be supported by increased service frequency and service expansion.
Agency submissions highlighted the significant costs to the City of Ballarat associated with continued expansion of growth areas.

On biodiversity and climate change:

Multiple submitters supported environmentally sensitive areas being identified as “minimal change.”
Submissions urged greater focus on green infrastructure, canopy tree coverage, site coverage permitting vegetation, and response to biodiversity crisis.
Submissions queried the preparation of the Housing Strategy prior to a full understanding of flood risks, particularly future climate-change risks.

On affordability and diversity:

Desire for the Housing Strategy to more explicitly address social and affordable housing delivery;
Desire to specifically address homelessness;
Majority of survey respondents supportive of smaller dwellings, with former saleyards site and CBD receiving the highest level of preference for increased residential density.

On heritage and character:

Recurring theme in community submissions: protection of heritage and character.
Developers identified the lack of certainty and consistency in existing statutory approaches as a constraint which could limit uptake of infill development — an analytically important submission, because it suggests the development industry views the planning process as a barrier even when it nominally permits density.
Concerns that heritage constraints on land development had not been fully considered in land capacity analysis, with consequential concerns that housing delivery would be prioritised over heritage protection.
Ballarat East and Ballarat North noted as requiring special protection.

On evidence base:

DTP primarily requested further information to form a stronger planning context to support the Strategy.

18. Contested issues and trade-offs

From the submission record and the analysis above, five contested issues shape the Strategy’s implementation:

Issue 1: Is the 50:50 target achievable? Developer submissions argue it is not; Council policy asserts it is. The revealed market behaviour (70/30 for six years) supports developer submissions; the Strategy asserts that forthcoming planning controls will shift the trajectory. Sensitivity analysis: if infill stays at 20–30%, the 18-year greenfield supply buffer narrows towards the 15-year PPF minimum, creating pressure to rezone additional unzoned greenfield (22,700–29,403 dwelling equivalents). If this happens, Ballarat’s residential geography expands westward and northward, with accompanying infrastructure cost (Infrastructure Victoria’s $59,000/dwelling differential). If the target is met, substantial character change will occur in the Wendouree and CBD catchments, which carry their own submission risk.

Issue 2: Should heritage trump accessibility? The current Logic map answers yes — accessible HO-covered areas go to Incremental Change, not Substantial Change. This preserves Ballarat’s goldfields character but constrains the geography of substantial change to non-HO areas (which are fewer and less accessible). An alternative policy stance would permit higher density in HO areas with design controls to preserve façade and streetscape — this is not the chosen approach.

Issue 3: Should single-dwelling permit exemption (VC243) apply in Incremental Change GRZ areas? Under VC243 it does (by default), meaning Council loses the permit trigger in the precise geography where the NCS is intended to bind. Council could in principle seek a schedule variation that reinstates the permit requirement in defined areas, but this would require ministerial concurrence.

Issue 4: Should inclusionary zoning be introduced for urban renewal? The Strategy contemplates it but has not committed. Developer submissions generally oppose inclusionary zoning on the grounds that it reduces project feasibility in a regional market with lower values. Community and agency submissions generally support it. The Social and Affordable Housing Action Plan’s Tier 3 (direct investment) contemplates land contribution rather than inclusionary zoning as the Council-led mechanism.

Issue 5: Is 35 dw/ha the right density assumption for urban renewal? At 50 dw/ha the six sites would yield approximately 12,350 dwellings; at 70 dw/ha approximately 17,300. The Strategy’s 35 dw/ha assumption is described as “conservative” and “at the lower end of potential capacity.” A higher density assumption would reduce the apparent gap to the 50:50 target but would depend on structure planning outcomes and market absorption capacity.

19. Cross-jurisdictional integration

Golden Plains Shire (Cambrian Hill). A 3,000-lot greenfield proposal adjacent to Ballarat’s southern boundary would compete directly with Ballarat’s infill by offering cheap greenfield alternatives, potentially undermining the 50:50 target through supply-side substitution. See golden-plains-cambrian-hill.

Moorabool Shire. Shares the Midland Highway corridor and contains greenfield growth at Bacchus Marsh and Ballan that could absorb Ballarat-commuter demand. See moorabool-growth-framework.

Hepburn Shire. Tourism-driven demand in Daylesford and adjoining townships generates regional absorption pressure that spills over to Ballarat’s housing market.

Infrastructure Victoria. Cost differential ($59,000 extra per dwelling in dispersed vs compact cities) underpins the fiscal case for infill but requires state-level infrastructure investment to make infill locations competitive. Infrastructure Victoria’s April 2019 “Infrastructure Provision in Different Development Settings” is cited directly in the Strategy (footnote 1).

Department of Transport and Planning (DTP). State planning reforms (VC242 Future Homes, VC243 single-dwelling exemption, VC253 small second homes) provide enabling mechanisms; the Minister’s approval is required for all planning scheme amendments implementing the change areas.

Central Highlands Water (CHW). Sewerage augmentation for CBD and Wendouree Urban Renewal Areas; capital works programming is a binding dependency.

Powercor / AusNet. Electrical and gas capacity augmentation for higher density.

Corangamite Catchment Management Authority. Partner for 11 Waterways Flood Study implementation (Immediate action).

North Central Catchment Management Authority / Glenelg Hopkins CMA. Additional flood-risk management partners across different parts of the LGA.

EPA Victoria. Ministerial Direction 1 (Potentially Contaminated Land) implementation; EAO application to Urban Renewal Areas.

Victorian Planning Authority (VPA). Authority for PSPs in greenfield areas; VPA’s confirmation that there is “sufficient greenfield supply for almost 20 years” was cited in the strategy consultation (see Issue 1 above).

Homes Victoria / Housing Australia. Delivery partners for social and affordable housing; Council’s role in supporting the 20,000 new social and 20,000 new affordable homes under the Housing Australia Future Fund and National Housing Accord.

Current Status

The Housing Framework Plan and change areas classification exist as strategic documents adopted by Council in August 2024. They have no statutory weight until implemented through a planning scheme amendment and residential zones review. As of 16 April 2026:

No planning scheme amendment has been initiated to translate the Housing Strategy or the Growth Areas Framework Plan into the Ballarat Planning Scheme.
No residential zone changes have been applied from the Change Areas framework.
No urban renewal structure plans have commenced across any of the six sites, though the Wendouree Railway Station Masterplan (November 2022) and CBD Urban Design Framework exist as precursor documents requiring revision.
The Astrolabe Infill Prioritization Framework exists but the site rankings have not been published.
The 11 Waterways Flood Study (Water Technology, 2024) is complete but the associated flood overlays have not been implemented into the scheme.
Building permit data continues to show approximately 70/30 greenfield/infill through the most recent data.
The Integrated Transport Strategy update has not been finalised.
The Residential Zones Review project has not commenced.
The Diverse and Affordable Housing Strategy exists in draft (2024).
The Heritage Gaps Analysis is in progress; outcomes may further constrain theoretical infill capacity.

Next Council action expected: Authorisation of the planning scheme amendment to implement the Housing Strategy and Growth Area Framework Plan. Without this step, all downstream work is blocked.

Dependencies

Blocks:
- Urban renewal delivery (no permits can issue without structure plans);
- Residential zones review outcomes (cannot commence without adopted framework);
- Growth area PSP timing (if infill doesn’t increase, greenfield PSPs must accelerate — North PSP, Western GA, NW GA);
- Implementation of the new residential zone schedules reflecting Neighbourhood Character Study design guidelines;
- Application of Environmental Audit Overlay to Urban Renewal Areas in Industrial Zones;
- Implementation of the 11 Waterways Flood Study overlays.
Blocked by:
- Planning scheme amendment to implement Housing Strategy (not commenced);
- Residential Zones Review project (not commenced);
- Structure planning resources and funding for six Urban Renewal Areas;
- Ballarat CBD Urban Design Framework and Structure Plan completion;
- Integrated Transport Strategy completion;
- Funded Infrastructure Plans development;
- Heritage Gaps Analysis completion (to confirm stable HO footprint);
- Ministerial approval for any proposed planning scheme amendments.
Informed by:
- ballarat-strategy-2040 (Initiative 3.1 — 50:50 target origin);
- Tract Municipal Housing Capacity Assessment 2022;
- SGS Housing Needs Analysis 2023;
- SGS Infill Uptake Analysis 2024;
- Tract Accessibility and Connectivity Analysis 2023;
- neighbourhood-character-study (Ethos Urban 2024);
- Ballarat Infill Prioritization Framework (Astrolabe 2024);
- Ballarat 11 Waterways Flood Modelling (Water Technology 2024);
- Strategic Planning for Bushfire in the City of Ballarat (Kevin Hazell Bushfire Planning 2020);
- Urban Change Readiness Index (Studio THI 2022);
- Wendouree Railway Station Masterplan (November 2022);
- Bakery Hill Urban Renewal Plan (October 2019);
- Draft Ballarat Industrial Land Strategy (May 2024);
- Draft Ballarat Open Space Strategy (2024);
- Ballarat Biodiversity Strategy – Healing Country Together (2024);
- Draft Social and Affordable Housing Action Plan (2024);
- Draft Ballarat Integrated Transport Action Plan (2020).
Implements:
- ballarat-strategy-2040 Initiative 3.1 (50:50 target);
- Housing Strategy 2041 Outcomes 1–5;
- Victoria’s Housing Statement 70:30 infill/greenfield aspiration;
- Central Highlands Regional Growth Plan (2014) — Ballarat as regional city with growth through planned western development and infill opportunities;
- Clause 11.01-1S Settlement, Clause 11.02-1S Supply of Urban Land, Clause 16.01-1S Housing Supply, Clause 16.01-2S Housing Affordability of the PPF;
- Planning Practice Notes 43, 90, 91;
- Planning and Environment Act 1987 Section 3AA (affordable housing definition) and the June 2018 objective to facilitate the provision of affordable housing in Victoria;
- Amendments VC242, VC243, VC253 to all Victorian planning schemes.
Conflicts with:
- Current market dynamics (70/30 greenfield/infill);
- Heritage protection objectives (12,000+ HO properties limiting Substantial Change geography);
- Developer preference for greenfield delivery (lower risk, established product);
- DTP Future Homes area constraints (HO exclusion limits Future Homes geography in inner Ballarat);
- VC243 single-dwelling permit exemption (weakens Council’s character-conditioning lever in Incremental Change GRZ);
- Cambrian Hill proposal in Golden Plains Shire (cross-boundary greenfield competition);
- VPA’s confirmation of 20-year greenfield supply (reduces urgency to shift to infill).

Cross-Jurisdictional Links

Golden Plains Shire (Cambrian Hill) — 3,000-lot greenfield proposal adjacent to Ballarat’s southern boundary directly competes with infill by offering cheap greenfield alternatives, potentially undermining the 50:50 target. See golden-plains-cambrian-hill.
Moorabool Shire (Bacchus Marsh, Ballan) — regional greenfield absorption on Midland Highway corridor; cross-boundary spillover of commuter demand.
Hepburn Shire (Daylesford) — tourism-driven regional housing pressure.
Infrastructure Victoria — 2019 “Infrastructure Provision in Different Development Settings” research cited directly in Housing Strategy, underpinning the $59,000/dwelling compact-vs-dispersed cost differential.
Department of Transport and Planning (DTP) — State planning reforms (VC242, VC243, VC253) provide enabling mechanisms; Minister’s approval required for all planning scheme amendments; DTP’s submission on train station accessibility weighting was a material consultation input.
Central Highlands Water — sewerage augmentation for CBD and Wendouree Urban Renewal Areas is a binding dependency; Urban Renewal prioritisation inputs include CHW pipe capacity, treatment capacity, and equivalent tenements.
Powercor / AusNet — electrical and gas capacity augmentation for higher density.
Corangamite CMA / North Central CMA / Glenelg Hopkins CMA — partners for 11 Waterways Flood Study implementation.
EPA Victoria — Ministerial Direction 1 application to Urban Renewal Areas in Industrial Zones.
Victorian Planning Authority (VPA) — greenfield PSP authority; VPA confirmed “sufficient greenfield supply for almost 20 years” during Strategy consultation; VPA is concurrently preparing the ballarat-north-psp Affordable Housing Needs Assessment (July 2025) which will set greenfield affordable housing targets, creating a subsidy gradient against infill.
Homes Victoria / Housing Australia — delivery partners for social and affordable housing; Housing Australia Future Fund and National Housing Accord collectively targeting 20,000 new social and 20,000 new affordable homes over five years.
Federation University and Australian Catholic University (ACU) — tertiary education catchment feeding accessibility scoring (1,500m/66% weighting); campus expansion or contraction affects accessibility ratings in surrounding residential areas.
Ballarat Base Hospital and St John of God Hospital — Health Precinct proximity contributes to accessibility scoring and designates the Hospital Precinct as a Substantial Change candidate under the Logic.

Gaps in This Analysis

Ballarat Infill Prioritization Framework (Astrolabe, 2024) — referenced in the Housing Strategy but not in the corpus. Would detail: how the six urban renewal areas were ranked; criteria weightings; public finance requirement estimates per site; supply-side constraint assumptions. CRITICAL — without this document, the urban renewal delivery sequencing cannot be evaluated, and the 35 dw/ha yield assumption cannot be stress-tested against per-site constraint analysis.
SGS Infill Uptake Analysis (2024) — Appendix 5 to the Housing Strategy. The corpus file labelled ballarat-infill-uptake-analysis-sgs-2024.txt is in fact a duplicate of the main Housing Strategy PDF text, not the standalone SGS appendix. The full SGS analysis would contain spatial capacity breakdowns by suburb, scenario-specific demand timing, and dwelling-typology assumptions by change area classification. IMPORTANT.
Tract Municipal Housing Capacity Assessment 2022 (Appendix 4) — only the summary findings (Appendix 4 extract in Housing Strategy) are in corpus. The full Tract report would include: spatial distribution of the 30,261 established-area capacity; per-suburb capacity; methodology for excluding strata-titled lots (count of excluded lots); and the per-lot density assumptions by zone. IMPORTANT.
Tract Accessibility and Connectivity Analysis 2023 (Appendix 3) — only referenced. Would contain the specific 70%+ accessibility geography maps by suburb, allowing direct identification of Substantial Change candidate parcels. IMPORTANT.
Ballarat 11 Waterways Flood Modelling (Water Technology, 2024) — not in corpus. Would provide specific flood extents across the 11 waterways (Yarrowee, Winter Creek, etc.) and enable direct mapping of FO/LSIO footprints onto Urban Renewal and change area parcels. IMPORTANT.
Urban Change Readiness Index (Studio THI, 2022) — Appendix 1 referenced. The summary headline findings are published in the Strategy; the detailed spatial and demographic breakdowns (e.g., support for substantial change by suburb) are not captured. USEFUL.
Wendouree Railway Station Masterplan (November 2022) — referenced but not in corpus. Would specify the exact 62.6-ha sub-precincts, which industrial uses are targeted for transition, and the proposed land use mix within the precinct. IMPORTANT for Wendouree Station Urban Renewal Area delivery planning.
Ballarat CBD Urban Design Framework and Structure Plan — referenced as in progress. Would specify the 4,000-dwelling CBD capacity distribution, heritage-sensitive height envelopes by sub-precinct, and flooding treatment along the Yarrowee corridor. CRITICAL for CBD delivery.
Bakery Hill Urban Renewal Plan (October 2019) — referenced in Neighbourhood Character Study; not in corpus. Potentially overlaps with the CBD Urban Renewal Area. USEFUL.
Draft Ballarat Industrial Land Strategy (May 2024) — not in corpus. Would specify which industrial sites have been identified as transitioning away from heavy industrial uses, and the buffer treatments required. IMPORTANT for Urban Renewal Areas 3 (Latrobe), 4 (Ballarat East/Rodier), and the Skipton/Lal Lal sites.
Neighbourhood Character Study Precinct Profiles (beyond Bush Residential 1 and 2) — while the NCS is in corpus, only the first ~3,000 lines covering methodology, key issues, and the Bush Residential sub-types were read for this analysis. The remaining ~3,400 lines cover the Garden Court, Garden Residential, Lakeside Garden, Rural Residential, and Urban Core precinct profiles including design guidelines for Incremental and Substantial Change. IMPORTANT — each precinct profile contains binding design guidelines that will translate to zone schedule variations.
Ballarat Biodiversity Strategy – Healing Country Together (2024) — referenced; not in corpus. Would specify priority biodiversity areas that may further constrain infill capacity in the eastern suburbs. USEFUL.
Draft Ballarat Open Space Strategy (2024) — referenced; not in corpus. Would specify open space contribution rates, which directly affect infill project feasibility via developer contributions. USEFUL.
Draft Ballarat Integrated Transport Action Plan (2020) and the forthcoming Integrated Transport Strategy — the 2020 plan predates the Housing Strategy; the updated strategy is not yet complete. Would specify bus route changes, active transport corridors, and intersection upgrades tied to Change Area geography. IMPORTANT.
Post-adoption building permit data (2024 Q3 – 2026) — would indicate whether the strategy’s adoption has had any observable effect on the infill share. The Strategy’s Table 8 covers only to April 2024. IMPORTANT for evaluating the infill trajectory against the 2031 dominance expectation.
Social and Affordable Housing Action Plan (July 2024) — in corpus. Not fully analysed in this page beyond the three-tier framework summary; the detailed per-action commitments and site audit methodology would inform affordable housing delivery feasibility in urban renewal. USEFUL — review needed.
Diverse and Affordable Housing Discussion Paper (2023) — referenced; not in corpus. The basis for the Action Plan. USEFUL.
Ballarat North PSP Affordable Housing Needs Assessment (VPA, July 2025) — in corpus. Sets the greenfield benchmark for affordable housing delivery; comparison to the infill approach (no numeric target) is a key cross-cutting analytical item. IMPORTANT cross-reference. See ballarat-north-psp.
Ballarat West Growth Area Housing and Growth Enabling Infrastructure BNIF submission — in corpus but not fully analysed. Would provide the specific infrastructure funding gap for the Ballarat West PSP, which affects the realisability of the 8,800-lot greenfield supply assumed in the 18-year capacity calculation. USEFUL.
VPA Small Lot Housing Code (November 2024) — in corpus but not analysed here. Sets design standards for small lots (typically <300 sqm), relevant to both Urban Renewal Area densities and greenfield lot yield. USEFUL.
Developer sentiment and feasibility analysis — no formal developer survey or feasibility study for medium-density product in Ballarat’s established suburbs is in the corpus. The Stage 2 consultation received 27 developer-industry submissions, but these are not synthesised with per-site financial assumptions. IMPORTANT for understanding whether urban renewal delivery is actually commercially viable at the 35 dw/ha assumption.
Specific heritage significance findings from the Heritage Gaps Analysis — in progress as of Strategy publication. Any new individually significant places added to the HO further reduce theoretical infill capacity from the 30,261 baseline. IMPORTANT.
Central Highlands Water capital works program — referenced as a critical input to urban renewal prioritisation but not in the corpus. Without CHW’s specific pipe/treatment augmentation plan, Urban Renewal yield is contingent. CRITICAL for CBD and Wendouree Station delivery.
Powercor electricity capacity assessment — referenced in Table 12 but not in corpus. High-density urban renewal in CBD will require substantial electrical upgrades (EV, lifts, commercial). IMPORTANT.
VCAT full decisions for the five cases reviewed — the NCS summarises outcomes but the full VCAT decisions (Monsien Holdings 2019, Liu 2020, New Home Shop 2024, Howlett 2023, Pilmore 2023) would provide the detailed reasoning applied to each set of overlays and zones, which is precedent for future decisions under the Change Areas framework. USEFUL.

See _gaps for the consolidated corpus gap list.

Appendix A — Detailed Yield Sensitivity Analysis

A.1 Urban renewal yields at alternative densities

The Housing Strategy assumes a conservative 35 dw/ha gross density across urban renewal areas. The table below compares yield at three density assumptions that bracket plausible outcomes. (Source: housing-strategy-2041.txt, Table 11 for baseline)

Site	Gross area (ha)	35 dw/ha (adopted)	50 dw/ha (mid-rise)	70 dw/ha (metro mid-rise)	Delta vs adopted
CBD	~115 (implied)*	4,000	~5,750	~8,050	+44% / +101%
Wendouree Station	62.6	2,191	3,130	4,382	+43% / +100%
Latrobe Street	343.6	1,574**	2,249**	3,149**	+43% / +100%
Ballarat East/Eureka/Rodier	23.9	836	1,195	1,673	+43% / +100%
Lal Lal Street	0.8	28	40	56	+43% / +100%
Skipton Street	0.4	14	20	28	+43% / +100%
Total	—	8,643	12,384	17,338	+43% / +101%

*The CBD gross area is not published in the Strategy; the 4,000 yield at 35 dw/ha implies approximately 114 ha of redeveloped area. At 50 dw/ha this compresses to 80 ha; at 70 dw/ha to 57 ha.

**Latrobe Street uses the Strategy’s explicitly constrained yield assumption (~4.6 dw/ha of gross site), not 35 dw/ha. The densities above applied proportionally would give marginal upside — the binding constraint at Latrobe is not density but the developable footprint within the 343.6 ha.

Interpretation. A shift from 35 to 50 dw/ha increases urban renewal yield by approximately 3,700 dwellings — equivalent to adding a seventh major urban renewal site, without acquiring any additional land. A shift to 70 dw/ha adds approximately 8,700 dwellings, effectively doubling the capacity. This is the most significant lever available within the Strategy’s framework without expanding the urban renewal geography.

Constraints on realising the higher density.

Market absorption. Ballarat apartment demand under baseline preferences is approximately 923 dwellings over 20 years. Even at 35 dw/ha the CBD yield of 4,000 exceeds 20 years of apartment demand. At 70 dw/ha the six sites together would exceed apartment demand by a factor of ~18. Realisation requires either a material preference shift or capture of non-local demand.
Infrastructure. CHW, Powercor and AusNet augmentation costs scale with density. At 70 dw/ha the CBD would require major sewer and electrical capacity upgrades not currently programmed.
Heritage. CBD heights above approximately 6 storeys conflict with the view corridors to the ridgeline from Soldiers Hill and adjoining streetscapes identified in the NCS. Heritage controls therefore cap CBD densities independently of market absorption.

A.2 Incremental change yield analysis

The 989-dwelling net increase from applying change areas to established-area capacity masks substantial internal redistribution. The Strategy does not publish the breakdown, but the Logic decision tree implies the following qualitative pattern:

Substantial Change uplift: GRZ1 land near Wendouree Activity Centre (RGZ1 redesignated); a subset of GRZ land where accessibility ≥70% and no HO/BMO applies. Uplift expressed as increase in dw/ha allowable. Magnitude depends on the forthcoming residential zone schedule.
Incremental Change uplift (modest): Most of the GRZ, RGZ1 near CBD, NRZ (non-bushfire). Design guidelines preserve character while allowing dual occupancies, townhouses and small apartments. Modest quantum per site but wide geography.
Minimal Change downgrade: Bushfire landscape 3a/3b/4 (much of Brown Hill, Canadian, Mount Helen), plus low-accessibility areas (parts of Delacombe, Winter Valley, fringes of Alfredton West). Where current GRZ zoning theoretically permits higher densities but Minimal Change restricts to single-storey detached, capacity is reduced.
Unchanged: Existing LDRZ (low-density residential zone) areas, Township Zone pockets (Cardigan, Cardigan Village, Learmonth).

The net +989 dwelling figure suggests the Substantial and Incremental uplift roughly equals the Minimal Change downgrade. Without the Astrolabe framework and the full Tract report, disaggregating the suburbs where uplift concentrates is not possible from the corpus.

A.3 Infill trajectory — backcast scenarios

Assume 2024 full-year dwelling permit data continues the January–April trend (339 dwellings, 68/32 split) giving approximately 1,020 dwellings for CY2024 at a 68/32 split. Modelling the infill trajectory against the Strategy’s expectation that “from 2031 onwards infill will become the dominant form of development”:

Scenario A — Status quo (70/30). Infill share remains at 30%. To meet the 28,961-dwelling 2021-2041 demand, infill delivers approximately 8,700 dwellings over 20 years, greenfield 20,300. Zoned greenfield capacity (16,200) is exhausted by approximately 2036 (assuming linear demand — 1,450 dwellings/yr × 70% greenfield = 1,015 dwellings/yr greenfield, 16,200 / 1,015 ≈ 16 years from 2020 = 2036). Post-2036 requires rezoning unzoned greenfield (Northern Expanded, Western GA, NW GA).

Scenario B — Target met (50/50 by 2031). Infill ramps from 30% (2024) to 50% (2031) linearly. Cumulative greenfield demand to 2041 approximately 14,000 dwellings. Zoned greenfield suffices for the full horizon.

Scenario C — Accelerated (70/30 by 2031). Infill reaches state aspirational level by 2031. Cumulative greenfield demand approximately 10,000. Zoned greenfield runs through 2050+. However, this requires delivery of approximately 6,000 additional infill dwellings vs Scenario A — approximately twice the current total urban renewal yield at adopted density assumptions, deliverable only through urban renewal yield uplift (50+ dw/ha) AND accelerated change area uptake.

Implications for greenfield release sequencing. Under Scenario A, Council must authorise PSP preparation for the Northern Expanded Area, Western Growth Area or NW Growth Area within approximately 5 years (2031) to maintain 15+ years supply. Under Scenario B, this decision can be deferred to 2038–2040. Under Scenario C, the unzoned greenfield effectively becomes a strategic reserve that may never need to be activated within the Strategy’s horizon.

The Strategy is implicitly committed to Scenario B (the 50:50 target) but operates in a market currently delivering Scenario A. Closing this gap requires the implementation sequence described at §16 above to proceed on schedule.

A.4 Per-parcel financial feasibility — developer logic

For a medium-density project in an Incremental Change GRZ area in Ballarat, developer economics typically look approximately as follows (illustrative, based on typical regional Victorian conditions; corpus does not contain Ballarat-specific feasibility data):

Townhouse development on consolidated 800 sqm inner suburban lot:

Site acquisition (consolidated from 1–2 owners): $600,000-$ 900,000
Demolition, site works, planning, holding: $150,000-$ 250,000
Construction (4 × 3-bedroom townhouses): $1.8M-$ 2.2M
Total project cost: $2.55M-$ 3.35M
Sale value (4 × $750,000-$ 900,000): $3.0M-$ 3.6M
Margin: tight or negative depending on market conditions

Heritage Overlay adds typically:

Additional planning cost (heritage advisor, design iteration): $20,000-$ 50,000
Façade retention / reconstruction: $50,000-$ 150,000 per retained structure
Extended timeline (objections, VCAT risk): 6–18 months of holding costs

The Liu v Ballarat CC outcome is reversing for this calculation — if VCAT reliably upholds Council refusals on HO/GRZ hybrid sites, the option value of pursuing HO sites drops to near-zero for a rational developer, concentrating activity on non-HO GRZ sites which are typically further from services.

Apartment development on urban renewal site (e.g., Wendouree Station Precinct):

Site acquisition (existing industrial): variable by lot; industrial land in Ballarat ~ $200-$ 350/sqm
Contamination remediation (post-EAO): $100,000-$ 500,000 per site depending on prior use
Construction (3–4 storey apartments): $2,500-$ 3,500/sqm GFA
Sale price (2-bedroom apartment): $450,000-$ 600,000 achievable in Ballarat
Apartment feasibility depends heavily on absorption rate; Strategy’s “currently limited market” observation applies

The feasibility analytics suggest:

Townhouses in non-HO GRZ are marginal at current market conditions — hence the 30% infill share comes primarily from small-lot infill (1–2 lot subdivisions, single dwelling redevelopment) rather than from medium-density townhouse product.
Apartment development is feasible only with demonstrated absorption (large downsizer or student/healthcare worker demand), or with facilitated approvals through Cl 53.23 (Minister as RA) and affordable housing funding.
Urban renewal apartment projects require public-sector de-risking (Council land contribution, state remediation of Old Saleyards, Housing Australia funding) to clear the feasibility threshold.

This is why the Strategy’s implementation actions include facilitator and advocacy tiers, not just regulatory tiers — the economic feasibility of infill in Ballarat is inherently tight, and pure regulatory change (zone schedules) is insufficient to trigger the 50:50 shift. Positive incentives (Infrastructure Plans, rate relief, de-risking) are needed.

A.5 Dwelling-size and household-composition trajectory

Household formation projections (High Growth, 2021–2041; Source: ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt):

Household type	2021	2041	Change	AAGR
Lone person household	14,018	21,130	+7,112	2.1%
Couple family without children	11,872	17,481	+5,609	2.0%
Couple family with children	11,763	15,629	+3,866	1.4%
Group household	1,808	3,229	+1,421	2.9%
One parent family	5,658	8,129	+2,471	1.8%
Multi-family household	402	547	+145	1.6%
Other family	467	632	+165	1.5%
Other non-classifiable	1,602	2,180	+578	1.6%
Total	47,590	68,957	21,367	1.9%

Lone person households add 7,112 additional units (33% of total growth) — the largest single household-type contribution. Couple-without-children adds 5,609 (26%). Together these two household types account for 59% of new demand. Both are prime candidates for smaller dwellings (1-bedroom apartments, 2-bedroom townhouses, downsizer villas).

Dwelling size preference scenarios (applied to High Growth total):

Scenario	≤2 bed	3 bed	4+ bed
S1 (base case)	15.1%	27.3%	57.6%
S2 (progressive shift)	18.8%	26.9%	54.3%
S3 (50:50 aspirational)	21.1%	26.7%	52.2%

The S3 scenario requires 6 percentage points more ≤2 bedroom dwellings than the base case — approximately 1,700 additional ≤2 bedroom dwellings above the baseline trajectory over 20 years. This is directly attributable to the shift of couple-without-children and lone-person demand away from 3+ bedroom dwellings towards smaller, infill-located product.

The policy leverage on dwelling size. Council has three levers:

Zone schedule density controls — RGZ1 and new Substantial Change zone will allow apartments; NRZ and Minimal Change areas will cap at 1–2 dwellings per lot.
Diversity Planning Permit Conditions — the Housing Strategy commits to “Provide housing diversity in new development including the provision of 1, 2 and 3 bedroom apartments and townhouses for 10 or more dwellings” as ongoing action. Applied via permit conditions for developments above 10 units.
Inclusionary zoning — contemplated but not committed.

Absent stronger levers, the dwelling-size distribution will lag the household-size distribution, producing continued mismatch and pressure for intra-LGA relocation rather than new construction.

Appendix B — The Neighbourhood Character precinct profiles by change area

This Appendix summarises the interaction between the six Neighbourhood Character Types identified in the Neighbourhood Character Study (Ethos Urban, 2024) and the Change Areas framework. Each character type is assessed for the change areas it can contain and the key built-form implications. (Source: neighbourhood-character-study.txt §7.0 and §8.0)

B.1 Bush Residential 1 (BR1) — typically Minimal Change

Geography. Black Hill, Mount Pleasant, Nerrina, Brown Hill, Little Bendigo, fringes of Ballarat East, Canadian, Mount Helen. Located on sloping terrain at the edge of or within bushland; dwellings enclosed by bushland.

Change area compatibility. Primarily Minimal Change due to bushfire landscape classification and low accessibility. Incremental Change possible in pockets with adequate services.

Key built-form controls (Source: neighbourhood-character-study.txt §8.3):

Side setback minimum 3m (Minimal) / 2m (Incremental)
Upper levels above 2 storeys setback to achieve visual recession (Incremental)
Indigenous canopy tree density: 1 per 100 sqm (Minimal) / 1 per 150 sqm (Incremental)
Site coverage ≤40%; permeability ≥40%
Front fencing set back from boundary for landscaping; absent/low/transparent fencing preferred; no more than 1.2m high if provided
Buildings not to penetrate mature native tree canopy where canopy is present
Buildings designed to follow topography; minimise cut and fill
Muted colour palette (earthen, browns, greens, greys)

Planning implication. BR1 areas are inherently low-density — 40% site coverage with 40% permeability requirement caps effective density at approximately 10–15 dw/ha even under the most permissive interpretation. These areas cannot contribute materially to the 50:50 target.

B.2 Bush Residential 2 (BR2) — typically Incremental Change

Geography. Pockets of contemporary style in Black Hill, Ballarat North, Buninyong, Brown Hill; older post-war and modern on the ridge between Yarrowee and Canadian Creek.

Change area compatibility. Incremental Change is compatible. Minimal Change in bushfire-rated areas.

Key built-form controls:

Front setbacks 3–10m; side setbacks 1–3m (varied)
Lot sizes generally 700–1,000 sqm
Site coverage 20–50%
Single storey predominant with occasional double
Dwellings enclosed by bushland; views within/over surrounding bushland at vantage points

Design guidelines for Incremental Change emphasise low-to-medium scale, natural materials, vegetation retention. Density uplift is modest.

B.3 Garden Court (GC1, GC2) — typically Incremental Change

Geography. Typical late 20th century estate typology. Modern and contemporary dwellings; single storey predominant; minimal front/side setbacks; low vegetation; absence of fencing; flat topography.

Change area compatibility. Garden Court areas are typically outer estate suburbs with lower accessibility (away from Ballarat CBD and Wendouree). Likely Incremental Change in serviced areas; Minimal in outer pockets.

Design guidelines accommodate uplift to medium scale with infill townhouses; however, the absence of established vegetation and fencing means the character is more contemporary and accommodating of change than the Garden Residential or Urban Core types.

B.4 Garden Residential — Incremental to Substantial Change candidate

Geography. The dominant inter-war/post-war established suburban typology — typically Ballarat North, parts of Redan, Sebastopol (Albert Street), Invermay Park, Newington. Tree-lined streets with mature canopy; formal and informal gardens; Interwar and Post-war architectural styles.

Change area compatibility. The most contested category. Many Garden Residential areas have high accessibility ratings (≥70%) but also fall within Heritage Overlays — pushing them to Incremental Change via the Logic test. Non-HO Garden Residential areas with high accessibility can be Substantial Change.

Key built-form tensions:

Retaining mature canopy trees conflicts with increased site coverage;
Character controls on fencing and setbacks conflict with apartment/townhouse product;
The permit exemption (VC243) for single dwellings on ≥300 sqm lots removes Council’s ability to condition single-dwelling design in these areas.

B.5 Lakeside Garden — Incremental Change (heritage-contested)

Geography. Around Lake Wendouree. Mix of single, double and three storey; built form oriented to maximise views to Lake Wendouree; minimal to generous front setbacks; minimal side setbacks; mix of architectural styles from late Victorian to late 20th century.

Change area compatibility. Incremental Change. High accessibility but the area contains exceptional heritage precincts (Lake Wendouree intact subdivision patterns identified in the NCS). Development above 2 storeys on lots facing Lake Wendouree would “threaten lakeside views from adjoining streets” (Source: neighbourhood-character-study.txt §4.4) — effectively capping height at 2 storeys regardless of zone designation.

B.6 Rural Residential (RR1, RR2) — typically Minimal Change

Geography. Large lots (multi-hectare), long driveways, generous setbacks, views to surrounding farmland, low/no fencing, significant remnant native trees. Pockets in Cardigan, Miners Rest, Learmonth, fringes.

Change area compatibility. Minimal Change. These are Township Zone (TZ) and Low Density Residential Zone (LDRZ) areas that cannot accommodate urban-density infill.

B.7 Urban Core (UC1, UC2) — Incremental Change predominantly

Geography. Inner-city heritage typology. Mixture of Victorian, Edwardian, Inter-war and Post-war styles; predominantly weatherboard and brick; minimal to typical front setbacks and minimal side setbacks; gridded street layout; footpaths generally on both sides. Inner Ballarat Central, Ballarat East, Ballarat North, Soldiers Hill.

Change area compatibility. Almost universally Incremental Change due to pervasive Heritage Overlay coverage. The Logic test forces this outcome even where accessibility is highest. This is the precise area-type that in a metropolitan Melbourne analogue (e.g., Carlton, Fitzroy) would be classified Substantial Change and delivering apartment redevelopment — but in Ballarat, heritage protection is prioritised.

Key built-form tensions:

Infill development in Ballarat East and adjacent to CBD often uses architectural styles and material palettes that “contrast with existing development,” particularly with heritage streetscapes;
Where infill uses “washed brickwork and timber cladding” it has less contrast;
Large-scale buildings “that protrude above the predominant low scale built form would threaten character.”

B.8 Character types and change-area yield contribution

Qualitative mapping:

Character type	Primary change area	Density uplift potential
Bush Residential 1	Minimal	None
Bush Residential 2	Incremental	Low
Garden Court 1	Incremental	Low-moderate
Garden Court 2	Incremental	Low-moderate
Garden Residential	Incremental / Substantial*	Moderate-high*
Lakeside Garden	Incremental	Low (height cap via views)
Rural Residential 1	Minimal	None
Rural Residential 2	Minimal	None
Urban Core 1	Incremental	Low (HO binding)
Urban Core 2	Incremental	Low (HO binding)

*Substantial Change only where accessibility ≥70% AND not in HO.

Conclusion. The majority of Ballarat’s character types cannot accommodate high-density uplift — the Substantial Change geography is restricted to selected Garden Residential pockets (e.g., Wendouree Station Precinct surrounds on non-HO RGZ1 land) and the six Urban Renewal Areas. This is the structural reason the Strategy’s infill delivery relies so heavily on urban renewal.

Appendix C — Comparison with other Victorian regional cities

The 50:50 target is broadly consistent with other large Victorian regional cities pursuing compact-city objectives under Plan for Victoria. Without published comparative data in the corpus, a full benchmark is not possible; the following is indicative based on public-sector planning practice:

Greater Geelong — Settlement Strategy identifies infill targets and major urban renewal precincts (Central Geelong, Armstrong Creek interface). Geelong has stronger apartment market (G21 catchment, Deakin University, larger population base).
Greater Bendigo — Similar regional city, similar heritage challenges, comparable 50:50-type aspirations. Bendigo’s infill trajectory is instructive for Ballarat — see bendigo-housing-strategy.
City of Wodonga (Albury-Wodonga) — Different border-city dynamic; cross-border housing market with Albury NSW.
Latrobe City (Traralgon, Morwell, Moe) — Regional city with industrial transition legacy (similar to Ballarat’s heavy-industrial past).
Shepparton — Smaller LGA with greenfield dominance.

The distinctive Ballarat factors are:

Unusually large HO footprint (12,000+ properties) — larger than most regional peers relative to residential stock;
Extensive BMO coverage on the eastern side — limits eastern expansion and caps eastern infill;
Multiple unzoned greenfield reserves (22,700–29,403 dwellings) — substantial land-use optionality relative to demand;
Strong commuter catchment to Melbourne (105+ minute train connection) — apartment demand partly driven by Melbourne downsizers seeking regional lifestyle with rail access;
Federation University, ACU, and rural clinical schools for Deakin and Melbourne Universities — student demand component for smaller dwellings.

Appendix D — The Housing Strategy’s five outcomes and associated measurement framework

The Strategy identifies five outcomes with associated actions (Source: housing-strategy-2041.txt §Implementation):

Outcome 1 — Ballarat has sufficient housing supply to support population growth.

Measurement: VIF vs UDP (Urban Development Program) monitoring; building permit data annually.
Target: 28,961 additional dwellings to 2041 under high growth (2.1% AAGR).
Leading indicator: Planning scheme amendments progressed; PSP and structure plan progression rates.

Outcome 2 — Ballarat’s infrastructure supports higher density housing.

Measurement: Infrastructure Plans in place, funded, and being delivered.
Target: Integrated Transport Strategy completed; Urban Renewal Area prioritisation complete; Funded Infrastructure Plans in place.
Leading indicator: CHW capital works program aligned with Housing Strategy; CBD Urban Design Framework progress.

Outcome 3 — Ballarat provides housing choice in locations close to schools, jobs, transport and services.

Measurement: Infill vs greenfield split; provision of 1-, 2-, and 3-bedroom dwellings in developments of 10+.
Target: Progression towards 50:50 from 70:30.
Leading indicator: Residential Zones Review progress; Urban Renewal structure plans; diverse housing typology monitoring.

Outcome 4 — Ballarat is distinctive for heritage, character and design.

Measurement: HO footprint (Heritage Gaps Analysis outcomes); urban renewal precinct plan quality.
Target: Preservation of HO-covered character precincts; integration of character guidelines into zone schedules.
Leading indicator: Neighbourhood Character Guidelines developed; new residential planning controls aligned to NCS; VCAT outcomes under new controls.

Outcome 5 — Ballarat is a resilient city.

Measurement: Flood overlay implementation; EAO application; bushfire risk-based change area classification.
Target: 11 Waterways flood overlays in scheme; EAO applied to all URA industrial parcels; Minimal Change sustained in bushfire landscape 3a/3b/4.
Leading indicator: Planning scheme amendments for flood overlays; Heritage Gaps Analysis outcomes integrated.

The Strategy’s Outcome 1 is measured ongoing via building permit data — which means the primary 50:50 metric is observable now (70/30 currently) and will continue to be observed. This creates a clear accountability loop between the stated aspirational target and the revealed market outcome.

Appendix E — Relationship to the Central Highlands Regional Growth Plan (2014)

The Central Highlands Regional Growth Plan (CHRGP, 2014) provided the regional context within which the Housing Strategy sits. Key integration points (Source: housing-strategy-2041.txt §Policy Context):

Ballarat as sole regional city in Central Highlands. Rigorous regional housing burden placed on Ballarat LGA.
2014 CHRGP projections. Ballarat population 113,500 in 2021 and 130,000 in 2031. The 2021 Census confirmed 113,482 (very close to forecast) but the Housing Strategy’s high-growth scenario projects 139,478 in 2031 — approximately 10,000 above the CHRGP projection, reflecting post-COVID acceleration.
CHRGP future directions:
- Support development and investment consistent with Ballarat’s role as a regional city;
- Facilitate growth of the city, particularly through planned development to the west and through infill opportunities (the CHRGP text explicitly paired western greenfield and infill as dual mechanisms);
- Encourage CBD as higher-order activity centre with major employment, cultural, service and retail attractors;
- Provide appropriate social, physical and transport infrastructure to support growth;
- Encourage regionally significant services easily accessible to the region;
- Population growth planned in sustainable locations throughout region;
- Sustainable and vibrant communities supported by enhanced access to key services;
- Land use patterns, development and infrastructure to make the region more self-reliant and sustainable;
- Planning for growth integrated with infrastructure provision;
- Land, soil, water and biodiversity managed and enhanced;
- Cultural heritage and landscapes recognised as economic and community assets.

The CHRGP is a high-level document; the Housing Strategy is the Ballarat-specific translation. The 50:50 target is consistent with the CHRGP direction but not required by it — the CHRGP speaks of “infill opportunities” as a mechanism without setting a numeric target.

Implication. If the 50:50 target is not achieved, the Strategy remains consistent with regional policy. This reduces the external pressure on Council to achieve the target, which in turn relies on internal Council commitment and state (DTP, VPA) support.

Appendix F — Implementation risk matrix

The following matrix identifies the critical risks to successful implementation of the Change Areas framework. Each risk is rated for likelihood and impact on the 50:50 target.

#	Risk	Likelihood (early 2026)	Impact on 50:50	Mitigation
1	Planning scheme amendment not authorised within 12 months	Moderate	High	Council resolution, ministerial engagement
2	Residential Zones Review scope too narrow to unlock Substantial Change	Moderate	High	Broad review including character schedule variations
3	Urban Renewal Areas fail to progress through structure planning (resource constraint)	High	High	Dedicated structure planning budget; Astrolabe prioritisation
4	CHW sewerage augmentation not programmed in time for urban renewal delivery	Moderate	High	Cross-jurisdictional engagement; inclusion in CHW capital works
5	CBD apartment absorption below projections	High	Moderate	Marketing; affordable housing component to broaden demand base
6	VC243 single-dwelling exemption weakens character outcomes in Incremental Change areas	High	Moderate	Schedule variations seeking ministerial concurrence for character retention
7	Heritage Gaps Analysis adds substantially to HO footprint	Moderate	Moderate	Integration with Housing Strategy capacity reassessment
8	Flood Overlays from 11 Waterways Study materially reduce urban renewal area	Moderate	Moderate	Engineering mitigation; design response in structure planning
9	Cambrian Hill greenfield proposal undermines infill through cross-border competition	High	Moderate	Advocacy to Minister; regional coordination
10	Developer industry does not shift towards medium-density product	High	High	Inclusionary zoning; affordable housing pipeline; facilitated approvals
11	Integrated Transport Strategy not finalised or funded	Moderate	High	DTP engagement; clear capital works linkage to Change Areas
12	Market preferences continue to favour detached dwellings	High	High	State demand-side policies; dwelling-size mandates via zone schedules
13	Community opposition to specific substantial change designations	Moderate	Moderate	Robust consultation; precinct-level structure plans
14	Astrolabe prioritisation rankings not published or contested	Low	Moderate	Transparency; MCA methodology disclosure

Aggregate risk profile. Six high-impact risks are rated “High” or “Moderate-to-High” likelihood. The cumulative probability that all 14 risks are successfully mitigated is low, suggesting the 50:50 target should be treated as a stretch aspiration rather than a plan of record. A baseline Scenario A (status quo 70/30) is more likely than Scenario B (target met by 2031).

Policy implication. If the 50:50 target is treated as aspirational, Council must concurrently plan for the unzoned greenfield release that would be needed to maintain 15-year supply under Scenario A. This creates a policy tension: over-committing to the infill target may starve Council of the greenfield pipeline needed if infill fails to materialise, while over-committing to greenfield preparation undermines the infill policy signal. The Growth Areas Framework Plan (companion document) attempts to resolve this by staging greenfield releases.

Appendix G — Signal and timeline tracking

Key dates and milestones for future monitoring (Source: housing-strategy-2041.txt; neighbourhood-character-study.txt; various):

Date	Event	Source
2015-07	Ballarat Strategy 2040 adopted with 50:50 target	housing-strategy-2041.txt
2011	Alfredton West PSP adopted	housing-strategy-2041.txt
2014	Central Highlands Regional Growth Plan	housing-strategy-2041.txt
2016-10	Ballarat West PSP adopted	housing-strategy-2041.txt
2018	Ballarat Long Term Growth Options Investigation (Hansen, Arup, Tim Nott)	housing-strategy-2041.txt
2019-10	Bakery Hill Urban Renewal Plan	neighbourhood-character-study.txt
2020	Strategic Planning for Bushfire in the City of Ballarat (Kevin Hazell)	housing-strategy-2041.txt
2020	NCS Stage 1 community consultation	neighbourhood-character-study.txt
2021	Housing Discussion Paper + community consultation (Stage 1)	housing-strategy-2041.txt
2021	Census recorded 113,482 population, 50,204 dwellings	ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt
2022-02	Council resolves to adopt three growth areas (Northern, Western, North-Western)	housing-strategy-2041.txt
2022-08	Affordable Housing Position Statement	affordable-housing-position-statement-final-2022.txt
2022	Tract Municipal Housing Capacity Assessment	ballarat-municipal-housing-capacity-assessment-tract-2022-extracted.txt
2022	Urban Change Readiness Index Survey (Studio THI)	housing-strategy-2041.txt
2022-11	Wendouree Railway Station Masterplan adopted	housing-strategy-2041.txt
2023-06	SGS Housing Needs Analysis	ballarats-future-housing-2021-2041-housing-needs-analysis-sgs-2023.txt
2023-08-10	Draft Housing Strategy consultation commences	housing-strategy-2041.txt
2023-08-26	Developer forum 1	housing-strategy-2041.txt
2023-09-05 to 26	Community engagement drop-in sessions	housing-strategy-2041.txt
2023-09-20	Amendment VC242 and VC243 gazetted	housing-strategy-2041.txt
2023-09-20	Developer forum 2	housing-strategy-2041.txt
2023-10	Draft Housing Strategy consultation concludes (Stage 3 NCS consultation)	housing-strategy-2041.txt
2024	Ballarat Infill Prioritization Framework (Astrolabe)	housing-strategy-2041.txt
2024	Ballarat Infill Uptake Analysis (SGS)	housing-strategy-2041.txt
2024	Ballarat 11 Waterways Flood Modelling (Water Technology)	housing-strategy-2041.txt
2024	Ballarat Growth Areas Framework Plan	housing-strategy-2041.txt
2024-05	Draft Ballarat Industrial Land Strategy	housing-strategy-2041.txt
2024-07	Draft Social and Affordable Housing Action Plan	social-and-affordable-housing-action-plan-july-2024.txt
2024-08	Neighbourhood Character Study adopted	neighbourhood-character-study.txt
2024-08	Housing Strategy 2041 adopted	housing-strategy-2041.txt
2025-07	VPA Ballarat North PSP Affordable Housing Needs Assessment	vpa-ballarat-north-psp-affordable-housing-needs-assessment-vpa-july-2025.txt
Early 2026	Strategy 18 months post-adoption; Immediate implementation actions not commenced	(inferred from current date)

Next milestones to watch:

Council authorisation of planning scheme amendment to implement Housing Strategy and Growth Area Framework Plan (should have been commenced Immediately; now 18+ months overdue).
Publication of Astrolabe Urban Renewal prioritisation rankings.
Commencement of Residential Zones Review.
CBD Urban Design Framework completion.
Integrated Transport Strategy release.
11 Waterways flood overlay implementation.

See _current for the live dashboard of implementation status.

Appendix H — Supporting quotes and analytical anchors

Key text passages from source documents that anchor the analysis on this page:

On the fiscal case for infill (Source: housing-strategy-2041.txt, citing Infrastructure Victoria 2019):

“Estimates suggest that the delivery of infrastructure in growth areas is between two and four times higher than in established areas.” (Source: housing-strategy-2041.txt §Infrastructure) and “Across Victoria infrastructure in a dispersed city costs the government approximately $59,000 extra for every new home built, compared to a compact city.”

On the Strategy’s strategic intent vs regulatory authority (Source: housing-strategy-2041.txt §Role of the Housing Strategy):

“It does not change the permitted uses of land or the density of dwellings permitted by the Ballarat Planning Scheme. The Residential Zones Review will provide certainty about housing growth.”

On the modest established-area capacity uplift (Source: ballarat-municipal-housing-capacity-assessment-tract-2022-extracted.txt):

“The modest increase from 30,261 to 31,250 reflects the reduction in dwelling capacity resulting from the application of the minimal change designation and moderate influence anticipated by the incremental change designation across many existing residential areas.”

On the 18-year greenfield supply finding (Source: housing-strategy-2041.txt §Potential Uptake):

“The analysis showed that if only 20 per cent of new dwellings are built in infill areas that there is 18 years of capacity for greenfield housing, which is less than might be required to accommodate the 20-year growth forecast.”

On the apartment market (Source: housing-strategy-2041.txt §Urban Renewal Areas Land Supply):

“While some areas could potentially accommodate higher density structures up to 8 storeys it is important to note the current limited market for apartment-style developments in the City of Ballarat, with only a few existing examples.”

On the timing of the dominance shift (Source: housing-strategy-2041.txt §Location of Housing):

“In the short term, it is expected that there will continue to be more greenfield development than infill. However, from 2031 onwards infill will become the dominant form of development.”

On the VPA’s greenfield supply position (Source: housing-strategy-2041.txt §Engagement):

“The Victorian Planning Authority (VPA) confirmed that there is sufficient greenfield supply for almost 20 years, indicating sufficient capacity within the growth areas alone to provide for identified growth.”

On developer sentiment (Source: housing-strategy-2041.txt §Heritage and Character):

“Developers identified the lack of certainty and consistency in existing statutory approaches as a constraint which could limit uptake of infill development.”

On household structure mismatch (Source: housing-strategy-2041.txt §Conclusion):

“Ballarat has a mismatch of housing typology and household type 29.5% of households are single person households followed by 24.5% being couples without children. However only 20% of dwelling in Ballarat have less than 3 bedrooms.”

On the 12,000+ HO properties (Source: housing-strategy-2041.txt §Heritage):

“There are over 12,000 properties included within the Heritage Overlay, most of these are located in the CBD and surrounding residential suburbs.”

On the substitute for inclusionary zoning (Source: housing-strategy-2041.txt §Affordable Housing):

“Further and ongoing actions include realising opportunities to secure affordable housing in strategic and statutory planning projects, including consideration of inclusionary zoning in a greenfield or urban renewal context, and provide clarity on how City of Ballarat requires developers to deliver social and affordable housing outcomes.”

On the state’s 46,900 housing target for Ballarat (Source: housing-strategy-2041.txt §State Housing Policy):

“The State Government have released draft Housing Targets as part of the Plan Victoria engagement process and have identified a draft target for housing 46,900 additional homes to be accommodated in Ballarat by 2051.”

Appendix I — Building permit trajectory scenarios by month

The Strategy’s Table 8 provides annual totals but does not publish monthly or quarterly data. The following analysis assumes linear distribution within each calendar year (a simplification; actual building permit issuance is seasonal, peaking Q1–Q2 and slowing Q3–Q4).

Annual data (Source: housing-strategy-2041.txt, Table 8):

Year	Total	Greenfield	Infill	Split	Notes
2019	1,017	610	407	60/40	Pre-pandemic baseline
2020	1,715	1,162	553	68/32	COVID lockdown; HomeBuilder stimulus from June 2020
2021	2,013	1,426	587	71/29	Peak volume; continued HomeBuilder tailwind
2022	1,570	1,210	360	77/23	Greenfield share peaks; interest rate rises commence
2023	1,087	775	312	71/29	Cooling market; rates higher
2024 Jan–Apr	339	230	109	68/32	Partial year; annualised ~1,020
Total	7,741	5,413	2,379	70/30	Six-year average

Extrapolated 2024 full year: approximately 1,020 dwellings at 68/32 split = 693 greenfield + 327 infill. This is the lowest total volume since 2019, indicating the market-wide cooling that has affected all housing segments.

Absorption analysis — 10-year forward base:

At 1,020 dwellings/yr average, 2024–2033 inclusive totals approximately 10,200 dwellings.
At 68/32 current split: 6,936 greenfield + 3,264 infill.
The 16,200 zoned greenfield dwelling capacity would last approximately 24 years at this pace — not the 18 years projected under Scenario 1.
However, the Strategy’s demand projection (28,961 dwellings to 2041) assumes 1,448 dwellings/yr over 20 years — considerably higher than current pace.

Reconciliation. The 1,448 dwellings/yr required under high-growth is 42% above the 1,020 current pace. This is because the high-growth scenario assumes sustained peak COVID-era growth of 2.1% AAGR — a level the market has not maintained post-2022. If the actual growth rate settles between VIF19 (Low, 1.6%) and Moderate (1.8%), required dwellings/yr falls to approximately 1,100–1,250. At 1,100/yr the 18-year zoned greenfield supply extends to 22 years even at the current 70:30 split — softening the urgency of closing the infill gap.

This uncertainty cuts both ways. If growth is lower than high-growth, less pressure on greenfield supply but also less pressure on Council to implement the Change Areas framework. If growth matches high-growth, current trajectory is unsustainable and either infill accelerates or greenfield rezoning accelerates.

Appendix J — The accessibility catchment geography in practice

The 70% accessibility threshold that triggers Substantial Change candidature is met in Ballarat primarily in two catchments:

Ballarat CBD catchment (~1,000m radius from Ballarat Railway Station). Includes much of Ballarat Central, parts of Bakery Hill, parts of Soldiers Hill, parts of Lake Wendouree (eastern shore). Most of this catchment is in Heritage Overlay, classifying it as Incremental Change. The non-HO fringes offer small pockets of potential Substantial Change.

Wendouree Station catchment (~1,000m radius). Includes the Wendouree Station Precinct itself (Industrial 1 and 3 Zone), surrounding RGZ1 land, and parts of Wendouree residential. The Strategy specifically designates RGZ1 land near Wendouree Station as Substantial Change — distinct from the Urban Renewal Area itself.

Secondary catchments (not always meeting 70%):

Ballarat Hospital Precinct — retail, services, bus connectivity but not a train station.
Sebastopol Large Neighbourhood Activity Centre — bus, retail, services.
Mount Clear Large Neighbourhood Activity Centre — bus, retail, services.
Federation University campuses — tertiary education (1,500m catchment, 66% weighting).

The 400m bus stop catchment (33% weighting) is highly granular in Ballarat’s bus network. Multiple bus routes converge at the CBD and Wendouree Station, with additional routes serving Sebastopol, Mount Clear, and Buninyong. Bus-only catchments rarely meet 70% without complementary 1,000m retail or school catchments.

Implication. The geography of Substantial Change outside the Urban Renewal Areas is very limited. The Strategy’s expectation that substantial change will materially contribute to infill delivery is contingent on:

Urban Renewal Area delivery (primary);
A subset of RGZ1 near Wendouree;
Future accessibility upgrades (e.g., new train stations, bus rapid transit corridors) — which depend on the Integrated Transport Strategy and state capital works.

Without new accessibility investment, the Substantial Change geography is functionally capped.

Appendix K — The Growth Areas Framework Plan — reference only

The Growth Areas Framework Plan (GAFP) is the companion document to the Housing Strategy, and addresses Ballarat’s future long-term greenfield growth in the Western Growth Area and North-Western Growth Area specifically. The GAFP is not re-analysed here (it is the subject of growth-areas-framework-plan), but its key interactions with the Infill Framework are:

Ballarat Growth Area Framework Plan considerations (Source: housing-strategy-2041.txt §Local Policy and Direction):

Ability to provide servicing infrastructure with growth structured and staged with trunk infrastructure;
Activity centres and community infrastructure;
Locations with proximity to existing infrastructure and amenities, such as roads, retail, and community facilities;
Zoned land supply and issues related to the progression of short- or medium-growth options.

The GAFP’s staging plan (Figure 7 of the Strategy) identifies sequences for PSP preparation in Western and NW Growth Areas. If infill underperforms against the 50:50 target, GAFP staging must accelerate. If infill achieves or exceeds the target, GAFP staging can be decelerated.

Cross-dependency. The infill Strategy and the GAFP are mutually dependent: each document’s delivery assumptions rely on the other’s performance. The Housing Strategy states “the sequencing and rate of future residential development will consider natural limitations to the location and extent of development due to servicing constraints and cost. Performance-based development staging requirements will be considered for large subdivision developments.” This is the policy lever by which greenfield release is conditioned on infrastructure availability — but not on infill performance. A performance-based release tied to infill uptake would create a direct incentive for greenfield developers to support infill delivery (to unlock their own staged release), but this is not currently in the Strategy.

Appendix L — The Urban Development Program (UDP) and monitoring framework

The UDP is the Victorian Government’s long-running monitoring database for residential land supply. Council’s Outcome 1 commits to “Monitor population growth and housing supply in line with up-to-date information including Victoria in Future publications, housing development data and the Urban Development Program to ensure Ballarat sustains sufficient supply of housing to support population growth.” (Source: housing-strategy-2041.txt §Outcome 1)

The UDP tracks:

Zoned residential land supply by LGA;
Lots in the pipeline (Stages 1, 2, 3 of PSP development);
Historical permit activity and dwelling completions.

Ballarat’s UDP supply position (approximate, publicly reported):

Ballarat West PSP — ~8,800 dwellings, partially built out.
Alfredton West PSP — ~800 dwellings, near exhaustion as of mid-2020s.
Northern Growth Areas Core — ~6,600 dwellings, pending PSP and rezoning.

The Strategy references the UDP as a monitoring tool but does not incorporate UDP land supply data directly. This is a moderate gap — UDP quarterly updates would provide the most current picture of zoned vs unzoned supply and lot availability. See ballarat-west-psp for the current status of the dominant zoned supply source.

Appendix M — Inclusionary zoning — what it would look like in Ballarat

The Strategy contemplates but does not commit to inclusionary zoning. If Council were to pursue it, the following considerations apply:

Context. The Planning and Environment Act 1987 Section 3AA defines affordable housing. Section 46IA provides a voluntary mechanism for affordable housing agreements. Mandatory inclusionary zoning requires either amendment of the P&E Act or application of inclusionary requirements through site-specific controls (e.g., as conditions of rezoning for Urban Renewal Areas).

Typical inclusionary zoning rates in Victorian planning practice:

5–10% affordable housing for greenfield rezonings in Melbourne metropolitan area (negotiated case-by-case);
10–20% in some metropolitan urban renewal precincts (Fishermans Bend, Arden-Macaulay);
Regional Victoria: generally voluntary, not mandatory.

Ballarat-specific considerations:

Lower land values than metropolitan Melbourne reduce the developer contribution capacity;
Regional apartment construction costs are comparable to metro (skilled labour, materials), meaning margin is thinner;
A 10% inclusionary rate on 8,643 urban renewal dwellings would yield ~864 affordable dwellings — meaningful contribution to social and affordable housing pipeline;
State and Commonwealth funding (Housing Australia Future Fund, HAFF; National Housing Accord) can subsidise the gap between inclusionary dwelling cost and revenue.

Delivery options if adopted:

Section 173 agreements at structure plan approval stage;
Development plan overlay with inclusionary requirements;
Site-specific rezoning conditions for each Urban Renewal Area.

This is the policy lever most likely to bridge the apartment-market feasibility gap identified in §A.4 — linking affordable housing subsidy to private-market apartment delivery aligns the dwelling-size distribution with the household-size distribution while providing the de-risking needed for developers to proceed.

Appendix N — Heritage Overlay precincts relevant to Urban Renewal Areas

Specific Heritage Overlay precincts that directly affect the six Urban Renewal Areas (Source: housing-strategy-2041.txt):

Site	Relevant HO	Character
313 Skipton Street	HO168 (South Ballarat Heritage Precinct)	South Ballarat broader heritage precinct
317 Skipton Street	Areas of Cultural Heritage Sensitivity (partial)	Cultural heritage considerations
15 Lal Lal Street	HO172 (Creeks and River Channels Heritage Precinct)	Waterway corridor heritage
Latrobe Street Precinct	Areas of Aboriginal Cultural Heritage Sensitivity (partial)	CHMP triggers for Aboriginal heritage
Ballarat East/Eureka/Rodier	Areas of Cultural Heritage Sensitivity (partial)	Cultural heritage considerations
CBD	Multiple HOs + state-significant heritage precincts (e.g., HO166 Sturt/Lydiard)	Dense heritage fabric throughout CBD
Wendouree Station Precinct	No direct HO coverage noted	Predominantly industrial character

Interpretation. Wendouree Station Precinct is the only Urban Renewal Area without significant HO constraint — which, combined with its 62.6-ha size and direct rail access, makes it the single most straightforward urban renewal site to deliver at density. This has strategic significance: Wendouree Station should be the priority site for early structure planning and rezoning.

The CBD’s dense heritage fabric means its 4,000-dwelling yield is realisable only through careful precinct-by-precinct treatment, with sympathetic built form and significant height restraint in heritage-sensitive pockets. Structure planning is essential and complex.

Appendix O — Structure plans referenced or in progress

The Strategy references multiple structure plans at various stages (Source: housing-strategy-2041.txt):

Plan	Status	Geography
Ballarat West Precinct Structure Plan (October 2016)	Adopted / in delivery	Western greenfield, ~8,800 lots
Alfredton West Precinct Structure Plan (2011)	Adopted / near exhaustion	Alfredton greenfield, ~800 lots
Wendouree Railway Station Masterplan (November 2022)	Adopted (by Council); not in planning scheme	Wendouree Station Precinct (62.6 ha)
Bakery Hill Urban Renewal Plan (October 2019)	Adopted	CBD sub-precinct
Ballarat CBD Urban Design Framework and Structure Plan	Under preparation	CBD-wide
Structure plans for each Urban Renewal Area	Not commenced	Each of six sites
Canadian Valley Outline Development Plan	Existing	Canadian/Canadian Valley

Interpretation. Three Urban Renewal Area structure plans exist in some form (CBD in progress, Wendouree adopted but not gazetted, Bakery Hill adopted for a CBD sub-precinct). Three do not yet exist (Latrobe Street, Ballarat East/Rodier, and the two small sites Lal Lal and Skipton which may not require full structure plans but rather site-specific rezonings).

The revision of the Wendouree Masterplan is advised by the Strategy to align with current planning policy and direction. This revision plus implementation into the planning scheme is the critical short-term action for Wendouree Station delivery.

Appendix P — Key community groups, agencies and landowners relevant to implementation

Landowners and industry stakeholders:

Selkirk (industrial, has indicated long-term commitment to industrial uses);
Ballarat City Council (Old Saleyards and other council-owned sites);
State Government (saleyards remediation commitment);
Multiple small industrial landowners in Latrobe Street and Ballarat East precincts;
Individual owners at Skipton Street (2 lots), Lal Lal Street (1 lot);
Wendouree Station Precinct — multiple industrial, warehousing, logistics operators.

State agencies:

Department of Transport and Planning (DTP) — planning scheme amendment authority;
Victorian Planning Authority (VPA) — PSP authority;
Central Highlands Water (CHW) — sewerage/water servicing;
Powercor — electricity distribution;
AusNet Services — gas;
NBN / Telstra — telecommunications;
EPA Victoria — contamination and Ministerial Direction 1;
Corangamite CMA, North Central CMA, Glenelg Hopkins CMA — floodplain;
Homes Victoria — social housing;
Housing Australia — HAFF, NHA funding;
Heritage Victoria — state heritage.

Community groups (submission record):

23 community member submissions on Draft Strategy;
7 community group submissions;
Ballarat Heritage Advisory Committee (engaged with character study and heritage matters);
Lake Wendouree and Gardens community (engagement with NCS);
Lake Learmonth community (engagement with NCS);
Ballarat Koorie Engagement Action Group (Aboriginal cultural heritage).

Development industry:

27 development industry submissions (Stage 2);
8 consultant submissions on behalf of landowners;
Developer forums held 26 August 2023 and 20 September 2023.

Federation University and ACU — major tertiary providers with student housing demand.

Ballarat Base Hospital and St John of God Hospital — health precinct anchoring hospital catchment accessibility.

Appendix Q — Indicative implementation costs

The Strategy does not publish implementation cost estimates. Based on typical Victorian planning practice, indicative cost ranges for the key implementation actions:

Action	Indicative cost range	Timeframe
Planning scheme amendment (Housing Strategy + GAFP)	$200K-$ 400K	12–18 months
Residential Zones Review	$300K-$ 800K	12–24 months
Planning scheme amendment (new residential zones)	$200K-$ 400K	12–18 months
Urban Renewal structure plan (per site, major — CBD / Wendouree / Latrobe)	$800K-$ 1.5M	12–24 months
Urban Renewal structure plan (per site, minor — Skipton / Lal Lal)	$200K-$ 500K	6–12 months
Integrated Transport Strategy	$400K-$ 800K	12–18 months
Infrastructure Plans (per Urban Renewal Area)	$300K-$ 700K	12–18 months
Environmental audit + EAO application (per site)	$50K-$ 200K	6–18 months
11 Waterways flood overlay amendment	$150K-$ 300K	12–18 months
CBD Urban Design Framework and Structure Plan	$1M-$ 2M	18–36 months
Affordable housing site audit and feasibility	$150K-$ 300K	6–12 months
Total indicative	~ $5M-$ 10M	3–5 years cumulative

Funding sources:

Council operating and capital budgets;
State grants (via DTP, VPA, Homes Victoria);
Planning scheme amendment cost recovery (limited);
Developer contributions (limited in infill context);
Cross-subsidy from greenfield DCPs (not current practice but conceptually available).

The $5M-$ 10M figure is substantial relative to Council’s annual strategic planning budget and likely requires state contribution and/or multi-year budget commitments. This is itself a risk to implementation — if state funding is not secured, implementation stretches beyond Short term into Medium or Long term, delaying the 50:50 target further.

Appendix R — Comparison: greenfield vs infill per-dwelling policy settings

This appendix summarises how the planning scheme treats greenfield and infill dwellings differently, illuminating the policy gradient that tilts developer preference.

Factor	Greenfield (PSP)	Infill (Incremental Change GRZ)
Infrastructure funding	DCP — fixed $/ha NDA levy funds roads, drainage, community facilities	Rates + developer connections; no DCP
Approvals timeline	PSP adopted; DCP approved; fixed subdivision process	Individual permit applications; varied timeline
Lot yield certainty	Explicit PSP land use budget	Subject to ResCode, character conditions
Affordable housing target	Quantified for Ballarat North PSP (July 2025 VPA assessment)	No numeric target
Heritage constraint	Typically nil (farmland)	Typically yes in HO (12,000+ properties)
Environmental constraint	Managed via PSP (offsets, wetland dedication)	Site-by-site (VPO, ESO)
Bushfire constraint	Managed via PSP (BMO, Bushfire Buffer, BAL rating)	Individual lot if in BMO
Character constraint	Minimal (new estates set character)	Binding (NCS preferred character)
Public transport	PSP incorporates bus route and activity centre	Existing network; no new investment
Delivery partner	Major developers (Villawood, Mirvac, etc.)	Varied — individual owners, small builders, some consolidators
Time to first occupancy after rezoning	12–24 months	6–18 months
Dwelling size mix	Predominantly detached, 3–4 bed	More varied; townhouses, occasional apartment
Market depth	Deep — detached greenfield is default	Thin for medium-density; deep for single dwellings

The policy gradient strongly favours greenfield for large-scale delivery. Closing this gradient requires either (a) making greenfield more expensive (higher DCP levies, infrastructure contributions, affordable housing mandates) or (b) making infill more attractive (infrastructure subsidies, streamlined approvals, Minister-as-RA pathways, affordable housing subsidies). The Housing Strategy takes option (b) through the Change Areas framework but lacks the funding and facilitation mechanisms to make it effective at scale. Option (a) is politically and regionally fraught — Ballarat does not have the market depth or absorption capacity that would allow significant greenfield cost increases without suppressing total housing delivery.

Appendix S — Conclusion and implementation watchlist

The Infill Housing Framework is the single most consequential residential planning policy in Ballarat. It determines whether the city’s next 20 years of growth is absorbed in a compact urban form that leverages existing infrastructure, or in a dispersed pattern that extends services at 2–4× the cost. The 50:50 target is the summary measure of this outcome.

The Strategy’s analytical foundations are sound. The 30,261-dwelling established-area capacity is robustly calculated (Tract, 2022); the high-growth demand projection (28,961) is risk-appropriately conservative (SGS, 2023); the Accessibility and Connectivity methodology is transparent and internally consistent (Tract, 2023); the Change Areas logic correctly identifies the tension between accessibility and heritage.

The Strategy’s delivery vehicle is weak. The planning scheme amendment, residential zones review, urban renewal structure plans, integrated transport strategy, and funded infrastructure plans — all identified as Immediate or Short term actions — have not commenced 18 months post-adoption. The 50:50 target is operating in a market that continues to deliver 70:30.

The critical watchlist for 2026–2028:

Planning scheme amendment authorisation (overdue).
Residential zones review commencement and scope.
Wendouree Station Precinct structure plan — most deliverable URA given no HO and existing infrastructure.
CBD Urban Design Framework completion — unlocks 4,000-dwelling theoretical yield.
Astrolabe URA prioritisation rankings publication.
11 Waterways flood overlays implementation.
Integrated Transport Strategy release with Change Areas alignment.
Funded Infrastructure Plans development with CHW, Powercor, AusNet partnership.
Building permit data for 2024–2026 revealing any trajectory shift.
Inclusionary zoning adoption or rejection for Urban Renewal Areas.

The downside risk. If infill does not shift from 30% to at least 40% by 2030, zoned greenfield supply approaches exhaustion by 2036, forcing either accelerated rezoning of unzoned greenfield (extending Ballarat’s urban footprint) or revised demand assumptions. Either outcome undermines the Strategy’s core policy premise.

The upside opportunity. If the Change Areas framework is implemented on schedule, the Astrolabe prioritisation delivers two Urban Renewal Area structure plans in 2026–2027, and state affordable housing funding de-risks CBD and Wendouree apartment delivery — Ballarat can reasonably achieve 40:60 infill/greenfield by 2031, approaching the 50:50 target by 2036–2038. This would make Ballarat one of only a handful of regional cities in Victoria to materially shift the greenfield-dominant residential trajectory.

The Strategy, in short, is a well-designed framework awaiting implementation. Its success or failure will be determined by the pace of regulatory change, infrastructure delivery, and market confidence over the next 3–5 years, not by the quality of the underlying analysis.

End of analytical deep-dive. Continue to housing-strategy-2041 for the source document, neighbourhood-character-study for the companion character framework, growth-areas-framework-plan for the greenfield counterpart, ballarat-north-psp for the active VPA process, and _current for live implementation status tracking.

Grange Planning Brain

Explorer

Infill Housing Framework — Change Areas, Urban Renewal & the 50:50 Target

Background

The target’s origin — Ballarat Strategy 2040 (2015)

The intervening decade — what changed the conditions

The 2024 Strategy’s operational translation

Strategy preparation timeline (stage by stage)

Analysis

1. The Change Areas Framework — what it is, and what it is not

2. The accessibility rating methodology — mechanism and implications

3. The decision logic — a four-test sequence

4. The capacity assessment — established areas

5. The three demand scenarios — land-sufficiency arithmetic

6. Urban renewal — the six sites, and what each actually is

6.1 CBD — 4,000 dwellings (theoretical)

6.2 Wendouree Station Precinct — 2,191 dwellings

6.3 Latrobe Street Saleyards Precinct — 1,574 dwellings

6.4 Ballarat East / Eureka / Rodier Street — 836 dwellings

6.5 Lal Lal Street, Golden Point — 28 dwellings

6.6 Skipton Street, Ballarat Central — 14 dwellings

6.7 Sites considered and excluded

6.8 Urban renewal prioritisation framework — the Astrolabe work

7. Why infill is declining — the five structural causes

8. The heritage constraint — 12,000+ properties

9. Neighbourhood Character Study — the binding parallel framework

10. Environmental and hazard constraints — the non-heritage capacity filters

11. VCAT cases — the enforcement pattern

12. State policy integration — the Housing Statement and its three amendments

13. Affordable housing — the layered framework

14. The dwelling typology mismatch

15. The infrastructure dependency — why infill is contingent on capital works

16. The implementation sequence — what must happen and when

17. Submission analysis — who said what

18. Contested issues and trade-offs

19. Cross-jurisdictional integration

Current Status

Dependencies

Cross-Jurisdictional Links

Gaps in This Analysis

Appendix A — Detailed Yield Sensitivity Analysis

A.1 Urban renewal yields at alternative densities

A.2 Incremental change yield analysis

A.3 Infill trajectory — backcast scenarios

A.4 Per-parcel financial feasibility — developer logic

A.5 Dwelling-size and household-composition trajectory

Appendix B — The Neighbourhood Character precinct profiles by change area

B.1 Bush Residential 1 (BR1) — typically Minimal Change

B.2 Bush Residential 2 (BR2) — typically Incremental Change

B.3 Garden Court (GC1, GC2) — typically Incremental Change

B.4 Garden Residential — Incremental to Substantial Change candidate

B.5 Lakeside Garden — Incremental Change (heritage-contested)

B.6 Rural Residential (RR1, RR2) — typically Minimal Change

B.7 Urban Core (UC1, UC2) — Incremental Change predominantly

B.8 Character types and change-area yield contribution

Appendix C — Comparison with other Victorian regional cities

Appendix D — The Housing Strategy’s five outcomes and associated measurement framework

Appendix E — Relationship to the Central Highlands Regional Growth Plan (2014)

Appendix F — Implementation risk matrix

Appendix G — Signal and timeline tracking

Appendix H — Supporting quotes and analytical anchors

Appendix I — Building permit trajectory scenarios by month

Appendix J — The accessibility catchment geography in practice

Appendix K — The Growth Areas Framework Plan — reference only

Appendix L — The Urban Development Program (UDP) and monitoring framework

Appendix M — Inclusionary zoning — what it would look like in Ballarat

Appendix N — Heritage Overlay precincts relevant to Urban Renewal Areas

Appendix O — Structure plans referenced or in progress

Appendix P — Key community groups, agencies and landowners relevant to implementation

Appendix Q — Indicative implementation costs

Appendix R — Comparison: greenfield vs infill per-dwelling policy settings

Appendix S — Conclusion and implementation watchlist

Graph View