title: Ballarat North Precinct Structure Plan (Amendment C256ball) council: ballarat state: vic category: growth-area classification: MAJOR status: exhibited last_compiled: 2026-04-17 source_docs:
- vpa-ballarat-north-psp-precinct-structure-plan-draft-for-public-consultation-september-2025.pdf
- vpa-ballarat-north-psp-development-contributions-plan-draft-for-public-consultation-september-2025.pdf
- vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.pdf
- vpa-ballarat-north-psp-draft-amendment-c256ball-instruction-sheet-public-consultation.pdf
- vpa-ballarat-north-psp-background-report-for-public-consultation-september-2025.pdf
- vpa-ballarat-north-psp-native-vegetation-precinct-plan-public-consultation-version-wsp-september-2025.pdf
- vpa-ballarat-north-psp-draft-integrated-transport-assessment-report-jacobs-august-2025.pdf
- vpa-ballarat-north-psp-strategic-transport-modelling-assessment-report-jacobs-july-2025.pdf
- vpa-ballarat-north-psp-utilities-assessment-report-stantec-march-2025.pdf
- vpa-ballarat-north-psp-energy-assessment-ausnet-october-2024.pdf
- vpa-ballarat-north-psp-iwm-and-drainage-assessment-arup-v3-july-2024-part-1-of-2.pdf
- vpa-ballarat-north-psp-iwm-and-drainage-assessment-arup-v3-july-2024-part-2-of-2.pdf
- vpa-ballarat-north-psp-stormwater-drainage-smec-july-2025.pdf
- vpa-ballarat-north-psp-biodiversity-assessment-report-wsp-august-2024.pdf
- vpa-ballarat-north-psp-land-capability-assessment-jacobs-october-2024_part-1-of-2.pdf
- vpa-ballarat-north-psp-land-capability-assessment-jacobs-october-2024_part-2-of-2_redacted.pdf
- vpa-ballarat-north-psp-landfill-gas-assessment-landserv-april-2025.pdf
- vpa-ballarat-north-psp-affordable-housing-needs-assessment-vpa-july-2025.pdf
- vpa-ballarat-north-psp-economic-retail-assessments-urbis-june-2024.pdf
- vpa-ballarat-north-psp-----draft-land-valuations-report-ey-parthenon-august-2025.pdf
- vpa-ballarat-north-psp-adverse-amenity-impact-assessment-ghd.-may-2024.pdf
- vpa-ballarat-north-psp-historical-post-contact-heritage-assessment-rba-july-2024.pdf
- vpa-ballarat-north-psp-bushfire-development-report-terramatrix-august-2025.pdf
- vpa-ballarat-north-psp-final-landscape-and-visual-assessment-mesh-april-2025.pdf
- vpa-ballarat-north-psp-geological-prospectivity-report-groundwork-october-2023.pdf
- vpa-ballarat-north-precinct-structure-plan-community-infrastructure-and-open-space-needs-assessment-vpa-october-2024.pdf
- vpa-ballarat-north-precinct-structure-plan-co-design-summary-vpa-october-2024.pdf
- vpa-ballarat-north-psp-pitching-sessions-summary-report-july-2023.pdf
- vpa-ballarat-north-vision-and-purpose-summary-report-december-2023.pdf
- vpa-ballarat-north-psp-arboricultural-and-assessment-report-treelogic-august-2024-part-1-of-2.pdf
- vpa-ballarat-north-psp-arboricultural-assessment-and-report-treelogic-august-2024-part-2-of-2.pdf
- vpa-ballarat-north-psp-bushfire-development-report-and-risk-assessment-ecology-and-heritage-partners-july-2024.pdf
- vpa-ballarat-north-psp-heritage-citation-bernera-homestead-88-olliers-road-mount-rowan-rba-april-2025.pdf
- vpa-ballarat-north-psp-heritage-citation-chalmers-homestead-15-sims-road-mount-rowan-rba-april-2025.pdf
- vpa-ballarat-north-psp-heritage-citation-hawthorn-farm-134-gillies-road-mount-rowan-rba-april-2025.pdf
- vpa-ballarat-north-psp-heritage-citation-hawthorn-park-112-olliers-road-mount-rowan-rba-april-2025.pdf
- vpa-ballarat-north-psp-heritage-citation-scotts-homestead-103-olliers-road-mount-rowan-rba-april-2025.pdf
- vpa-ballarat-north-psp-scotts-homestead-statement-of-significance-may-2025.pdf
- vpa-ballarat-north-psp-hawthorn-park-statement-of-significance-may-2025.pdf
- vpa-ballarat-north-psp-hawthorn-farm-statement-of-significance-may-2025.pdf
- vpa-ballarat-north-psp-chalmers-homestead-statement-of-significance-may-2025.pdf
- vpa-ballarat-north-psp-bernera-homestead-statement-of-significance-may-2025.pdf
- vpa-ballarat-north-psp-draft-amendment-c256ball-submission-01-through-63-redacted.pdf
Ballarat North Precinct Structure Plan (Amendment C256ball)
Current Production Status
C256ball current status: exhibition and the reserved March 2026 SAC hearing window have passed; SAC report, Ministerial decision, approval and gazettal are not in corpus.
Current Production Status
C256ball current status: exhibition and the reserved March 2026 SAC hearing window have passed; SAC report, Ministerial decision, approval and gazettal are not in corpus.
Current Production Status
C256ball current status: exhibition and the reserved March 2026 SAC hearing window have passed; SAC report, Ministerial decision, approval and gazettal are not in corpus.
The Ballarat North PSP is the most significant planning initiative in regional Victoria currently in preparation. It proposes to develop 571 hectares of predominantly pastoral land approximately 7 km north-west of the Ballarat CBD into a residential community of approximately 5,523 dwellings housing 15,467 people, supported by 184.2 million in development contributions. The amendment was exhibited for public consultation from 19 September to 20 October 2025 and attracted at least 63 submissions. The reserved Standing Advisory Committee hearing window in March 2026 has now passed, but this corpus does not contain a SAC report, Ministerial decision or gazettal outcome. The PSP delivers approximately 30% of Ballarat's greenfield housing target of 18,900 homes under Plan for Victoria and 12% of the total municipal housing target of 46,900 homes to 2051. At a DCP levy rate of 672,901 per hectare of Net Developable Area, this is a high-cost regional PSP with contested infrastructure apportionment, a divisive 13% affordable housing target, and binding infrastructure constraints around water, sewer, and electricity that will determine whether development can commence as planned in 2028. (Source: vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt; vpa-ballarat-north-psp-precinct-structure-plan-draft-for-public-consultation-september-2025.txt)
Background
Strategic origins
The Ballarat North PSP has its strategic genesis in three documents. First, the Ballarat Long Term Growth Options Investigation (Hansen Partnership, Arup, and Tim Nott, August 2018) assessed four potential greenfield growth areas and found the Northern Growth Area the most viable for development. Second, the Ballarat Housing Strategy 2041 (August 2024) formally identifies the Northern Growth Area as Council’s priority growth area for short-to-medium-term land supply, establishing the policy basis for VPA involvement. Third, in August 2022 the then Minister for Planning Lizzie Blandthorn MP appointed the Victorian Planning Authority as Planning Authority to prepare a PSP and DCP for the Northern Growth Area. (Source: vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt)
The PSP is nominated as a priority planning project in Victoria’s Housing Statement — The Decade Ahead 2024-2034, contributing approximately 5,600 dwellings and 1,000 jobs to the Housing Statement’s target of 60,000 homes across 21 priority projects. Plan for Victoria identifies Ballarat as a Major Regional City with a housing target of 46,900 new homes by 2051, of which 18,900 (40%) should be in greenfield areas. The Ballarat North PSP at approximately 5,600 dwellings represents 30% of that greenfield target. (Source: vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt)
The PSP 2.0 process
Ballarat North was selected as the winning submission from four shortlisted for the VPA’s PSP 2.0 Innovation Pathway Pilot Program, exploring five innovation areas: (1) sustainable embedded energy networks, (2) sustainable subdivisions, (3) biodiversity corridors, (4) new approaches to waste management, and (5) social and affordable housing. This pilot status explains several provisions in the PSP that exceed standard regional requirements, including the 10 kW DC solar minimum per dwelling, 13.6 kWh battery storage recommendation, and the 13% affordable housing target. (Source: vpa-ballarat-north-vision-and-purpose-summary-report-december-2023.txt)
The preparation process followed the VPA’s progressive certainty approach, with pitching sessions in April 2023 (31 sessions covering 77% of precinct land area), a Vision and Purpose survey in September 2023 (41 responses, 70% from landowners), a co-design workshop on 17 July 2024 (62 stakeholders at The Goods Shed Ballarat), and plan preparation through 2024-2025 before public exhibition in September 2025. (Source: vpa-ballarat-north-psp-pitching-sessions-summary-report-july-2023.txt; vpa-ballarat-north-vision-and-purpose-summary-report-december-2023.txt; vpa-ballarat-north-precinct-structure-plan-co-design-summary-vpa-october-2024.txt)
Core area versus expanded area
The Northern Growth Area is divided into two components:
- Core area: approximately 571 hectares south of Cummins Road, the subject of this PSP and Amendment C256ball.
- Expanded area: approximately 272 hectares north of Cummins Road, currently zoned Farming Zone, excluded from this amendment but subject to an indicative Framework Plan included as Appendix 6 of the PSP.
This division is one of the most contested aspects of the amendment, with multiple submissions (Submissions 02, 16, 28, 29, 37, 48, 58) arguing that the expanded area should be rezoned concurrently to avoid duplicate PSP costs, ensure DCP funding equity, and deliver integrated infrastructure. The PSP’s staging criteria for the expanded area require a separate future amendment, with timing dependent on land supply monitoring. (Source: vpa-ballarat-north-psp-precinct-structure-plan-draft-for-public-consultation-september-2025.txt; vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt)
Analysis
1. Land Supply, Yield, and the Net Developable Area Problem
The headline precinct area of 570.61 hectares is significantly eroded by constraints to produce a Net Developable Area (NDA) of just 273.72 hectares — only 47.97% of the total precinct. This is the single most important number in the PSP for development feasibility. Multiple submissions contest this figure, with Submission 48 specifically noting that the Ballarat West PSP achieved 74% NDA and arguing that 47.97% renders the Ballarat North PSP unviable. (Source: vpa-ballarat-north-psp-development-contributions-plan-draft-for-public-consultation-september-2025.txt)
The land use budget breaks down as follows:
| Category | Area (ha) | % of Total Precinct | % of NDA |
|---|---|---|---|
| Net Developable Area (Residential) | 273.72 | 47.97% | — |
| Transport (road reserves) | 16.82 | 2.9% | 6.14% |
| Community & Education | 28.98 | 5.1% | 10.59% |
| Open Space — Service (conservation, drainage, encumbered, landscape) | 123.47 | 21.6% | 45.11% |
| Open Space — Credited (sports reserves, local parks) | 27.63 | 4.8% | 10.09% |
| Open Space — Regional (municipal, council-funded) | 90.35 | 15.8% | 33.01% |
| Investigation Area | 9.64 | 1.7% | 3.52% |
(Source: vpa-ballarat-north-psp-development-contributions-plan-draft-for-public-consultation-september-2025.txt, Table 6)
The dominant constraint is open space, which consumes 241.45 hectares (42.3% of the total precinct). Of this, 90.35 hectares is municipal open space — predominantly the Ballarat Town Common (Property 45, 87.90 ha, 0% NDA) — which is council-funded and not included in the DCP. The Town Common’s inclusion in the precinct boundary inflates the gross area while producing zero developable land, which is why the NDA percentage appears so low relative to benchmarks. Submission 26 explicitly challenges this, noting that the Town Common is included in open space calculations “despite commitment it would be left untouched.” (Source: vpa-ballarat-north-psp-development-contributions-plan-draft-for-public-consultation-september-2025.txt, Appendix A)
Excluding the Town Common and other non-developable municipal open space from the gross area, the effective precinct area is approximately 480 hectares, producing an adjusted NDA ratio of approximately 57% — still below the Ballarat West benchmark of 74% but more defensible as a planning outcome given the significant drainage, heritage, and contamination constraints unique to this precinct.
Parcel-level yield distribution
The NDA is unevenly distributed across the precinct’s 69 properties. Key parcels include:
| PSP Property ID | Total Area (ha) | NDA (ha) | NDA % | Key Constraint |
|---|---|---|---|---|
| 45 | 87.90 | 0.00 | 0.00% | Ballarat Town Common (entire lot) |
| 43 | 63.03 | 45.37 | 71.97% | Largest developable parcel |
| 44 | 52.59 | 29.54 | 56.16% | Drainage, landscape values |
| 51 | 50.70 | 23.86 | 47.06% | Schools, heritage, drainage |
| 42 | 41.00 | 26.60 | 64.88% | Schools, sports reserve |
| 58 | 22.57 | 22.07 | 97.77% | Minimal constraints |
| 96 | 18.06 | 10.92 | 60.48% | Eastern sub-precinct |
| 46 | 25.68 | 19.00 | 74.00% | Mount Rowan interface |
(Source: vpa-ballarat-north-psp-development-contributions-plan-draft-for-public-consultation-september-2025.txt, Appendix A)
Several properties have zero NDA despite significant total area: Property 41 (9.45 ha, the subject of Submission 22 which contests PAO06 drainage), Property 47 (5.49 ha), Property 50 (4.28 ha), and Properties 62-64 (combined 5.21 ha). These landowners receive no development yield from the PSP but may still face holding costs — a significant equity issue highlighted by Submission 22, which documents annual holding costs of $95,344.21 in land tax and council rates for a property that will produce zero developable area.
Dwelling yield
The PSP proposes a minimum average density of 20 dwellings per net developable hectare (dw/NDHa) across the precinct, with two density zones:
| Zone | NDA (ha) | Target Density (dw/NDHa) | Estimated Dwellings |
|---|---|---|---|
| Area of increased density | 109 | 25 | 2,721 |
| Balance area | 165 | 17 | 2,802 |
| Total | 274 | ~20 | 5,523 |
(Source: vpa-ballarat-north-psp-precinct-structure-plan-draft-for-public-consultation-september-2025.txt, Table 4)
The area of increased density (25 dw/NDHa) applies to land within a 400m w
Section clipped to keep the wiki page within the production size contract. Source files remain in the repository/extracted evidence corpus.
Current Status
As of April 2026, the Ballarat North PSP and Amendment C256ball are at the following stage in the Victorian amendment lifecycle:
- Exhibition completed: 19 September - 20 October 2025
- Submissions received: At least 63
- SAC Directions Hearing: Week commencing 9 February 2026
- SAC Panel Hearing: Week commencing 16 March 2026
- Target completion: June 2026 (Victoria’s Housing Statement deadline)
The VPA is operating under a “progressive certainty” approach, meaning some technical work (drainage functional designs, transport functional designs and costings) is being finalised concurrently with the SAC process. Placeholder designs and costings in the DCP will be superseded by detailed consultant work before gazettal. (Source: vpa-ballarat-north-psp-background-report-for-public-consultation-september-2025.txt)
Key decisions pending from the SAC:
- Expanded area: Whether the Framework Plan approach is adequate or whether concurrent rezoning should be pursued.
- DCP apportionment: Whether Midland Highway items should be reduced from 100% to 50-60%; whether DR-01 should be removed from the DCP; whether Cummins Road 50% external apportionment is justified.
- Affordable housing: Whether the 13% target and S173 mechanism should be retained, modified, or removed.
- School location: Whether the south-east P-6 school should remain on DFC land or relocate north of Olliers Road.
- EPA concerns: Whether the Boral Asphalt buffer should be 500m or 1,000m; whether risk assessments should be mandatory; whether a Midland Highway noise buffer is required.
- Drainage placeholder costs: Whether the DCP should proceed with SMEC placeholders or await detailed functional designs.
Dependencies
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Blocks: The expanded area (272 ha, approximately 2,600-3,500 additional lots) cannot proceed to rezoning until the core PSP is gazetted and staging criteria are met. Three DCP items deferred to the expanded area (RD-01-3, IN-03, IN-06) have no funding mechanism until the expanded area amendment proceeds. Community infrastructure items at 50% apportionment (SR-01, CI-02, SP-01) require expanded area DCP funding for the remaining 50%.
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Blocked by:
- Central Highlands Water sewer upgrade (PR23 capital works, Burrumbeet Creek SPS upgrade) — must be complete before Stage 1 development can commence, expected 2028.
- Central Highlands Water Invermay Trunk Main duplication — without this, water supply limited to approximately 1,000-1,500 lots. Not yet committed in CHW capital works program.
- Powercor Ballarat North Zone Substation upgrade — must be complete before Stage 1. Ballarat East ZSS under development, included in Powercor’s 10-year capital plan.
- SAC hearing and Minister’s decision — expected mid-2026.
- Detailed drainage functional designs — replacing SMEC placeholder costings, required before gazettal.
- CHW Class A recycled water business case — expected March 2026.
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Informed by: 30+ technical background studies including Jacobs (transport, land capability), Arup (IWM/drainage), SMEC (stormwater drainage), WSP (biodiversity, NVPP), Stantec (utilities), AusNet (energy), GHD (adverse amenity), RBA (heritage), TerraMatrix (bushfire), Mesh (landscape), EY-Parthenon (land valuations), Urbis (economic/retail), Landserv (landfill gas), Groundwork Plus (geological prospectivity), Treelogic (arboricultural).
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Implements:
- Ballarat Housing Strategy 2041 — Northern Growth Area identified as priority growth area
- Plan for Victoria — 18,900 greenfield homes target for City of Ballarat
- Victoria’s Housing Statement — The Decade Ahead 2024-2034 — nominated priority project
- Central Highlands Regional Growth Plan — Ballarat as regional city for growth
- Precinct Structure Planning Guidelines: New Communities in Victoria (VPA, 2021)
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Conflicts with:
- The Northern Growth Area broader framework regarding expanded area timing
- EPA Victoria’s recommended 1,000m buffer for Boral Asphalt vs PSP’s 500m buffer
- Existing SUZ13 (Dowling Forest Equine Precinct) restrictions on adjacent land
- Potential tension between the 13% affordable housing target and development feasibility at $672,901/NDHa DCP levy
Cross-Jurisdictional Links
-
Central Highlands Water: CHW is the statutory water corporation responsible for water supply and sewer services. Its PR23 capital works program (Ballarat Sewer Growth Project — Northern Growth Area, completion 2028) is the critical enabling infrastructure for Stage 1. CHW’s Invermay Trunk Main duplication capacity constrains total precinct yield. CHW is also developing a Class A recycled water business case from the Ballarat North Water Reclamation Plant (expected March 2026). (Source: vpa-ballarat-north-psp-utilities-assessment-report-stantec-march-2025.txt; Submission 56)
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Powercor / AusNet: Electricity distribution network upgrades (BAN ZSS upgrade, BAE ZSS construction) are required before full build-out. The 10-year capital plan includes the BAE ZSS but timeline is uncertain. AusNet’s energy assessment sets ambitious net-zero energy targets (67.4 MW solar, 90.6 MWh battery storage across the precinct). (Source: vpa-ballarat-north-psp-energy-assessment-ausnet-october-2024.txt; Submission 12)
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Glenelg Hopkins CMA: Responsible authority for Burrumbeet Creek floodplain management. The amendment requires utility coordination plans and drainage/fill strategies to be prepared to the satisfaction of GHCMA. The CMA’s 2024 climate change guidelines (4.5 degrees C, 2100 horizon) drive the near-doubling of design peak flows. (Source: vpa-ballarat-north-psp-stormwater-drainage-smec-july-2025.txt)
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Country Fire Authority: Agreed to UGZ3 bushfire management plan requirements. CFA views were sought during preparation of the TerraMatrix bushfire assessment. (Source: vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt)
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Department of Transport and Planning (DTP): The VPA (now part of DTP) is the planning authority. DTP will need to investigate Western Freeway interchange upgrades — not included in the DCP and likely requiring state funding — as V/C ratios reach 1.0-1.2 by 2051. (Source: vpa-ballarat-north-psp-draft-integrated-transport-assessment-report-jacobs-august-2025.txt)
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EPA Victoria: Significant unresolved issues regarding Boral Asphalt buffer distance, Midland Highway noise, and whether amenity risk assessments should be mandatory or discretionary. (Source: Submission 62)
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Wadawurrung Traditional Owners Aboriginal Corporation (WTOAC): The Registered Aboriginal Party. The precinct is on Wadawurrung Country. The Paleert Tjaara Dja (Wadawurrung Country Plan 2020-2030) values inform PSP requirements around cultural heritage, waterways, and biodiversity. Cultural Heritage Management Plans will be required for development within areas of Aboriginal Cultural Heritage Sensitivity. (Source: vpa-ballarat-north-psp-precinct-structure-plan-draft-for-public-consultation-september-2025.txt)
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Adjacent councils: The Northern Growth Area is Ballarat’s only significant greenfield growth front following substantial build-out in Ballarat West. If the expanded area does not proceed, Ballarat’s greenfield land supply may be insufficient to meet Plan for Victoria targets. Submission 49 (INTEGRA, local Ballarat developer) argues “BNPSP development constraints and costs are unlikely to provide sufficient housing supply to offset decline in Ballarat West PSP and Alfredton West PSP.” (Source: Submission 49)
Gaps in This Analysis
This analysis is based on 63+ documents from the VPA project page, providing substantial depth. However, the following gaps limit completeness:
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Community Infrastructure and Open Space Needs Assessment (VPA, October 2024): PDF extraction failed — the text renders as orphaned bullet symbols without content. Key outputs are known from cross-references in other documents and submissions but primary data on catchment analysis, infrastructure benchmarks, and gap assessments is not available.
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Submissions 47, 50, 51, 52, 55, 57, 60, 63: These submissions exceeded file size limits or were attachment-only PDFs not recoverable from text extraction. Some may contain substantive technical arguments from major landowners or agencies.
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CHIA Vic submission (Submission 43): Only the table of contents was extracted; the substantive content (4 recommendations on affordable housing) is not available.
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Detailed drainage functional designs: The VPA acknowledges these will supersede SMEC placeholder costings before gazettal, meaning the $66.1 million drainage figure may change materially.
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SAC hearing outcomes: The Directions Hearing (week of 9 February 2026) and Panel Hearing (week of 16 March 2026) have likely occurred by the date of this compilation but outcomes are not in the corpus.
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CHW capital works program details: The PR23 Ballarat Sewer Growth Project commitment and Invermay Trunk Main duplication status require verification from CHW’s published capital works program or annual report.
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Powercor network investment plan: Timing and commitment for the BAE ZSS at York Street requires verification from Powercor’s regulatory submissions or distribution annual planning report.
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Aboriginal cultural heritage: The RBA heritage assessment explicitly excludes Aboriginal cultural heritage. A separate CHMP process will be required but no Aboriginal cultural values assessment report was identified in the corpus, despite references to WTOAC engagement throughout the PSP preparation.
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Miners Rest Mitigation Strategy (2021): Referenced in Submission 22 regarding Burrumbeet Creek remediation and flood mitigation but not in the corpus.
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Adjacent council plans: The impact on Hepburn Shire (Creswick growth), Moorabool Shire (western growth corridor), and Mitchell Shire (broader regional housing supply) is not assessed.
For the full gaps register, see _gaps.
Size Contract Note
This page was compacted for UI and Obsidian readability. The underlying source documents and extracted text remain in the evidence corpus.
Ballarat North PSP/C256ball is the authoritative page for the broader PSP technical and submissions corpus. Narrow DCP pages should be read as cost-table summaries and not as statements that the wider PSP evidence package is absent.
Post-Hearing Status Guardrail
As at 31 May 2026, any March 2026 SAC or Panel hearing date for Ballarat North/C256ball should be read as a past procedural milestone, not as a future event. The available corpus does not contain a SAC report, Panel report, Ministerial decision or gazettal outcome after those hearing windows, so the defensible status is “hearing window passed; outcome not in corpus”. This keeps the page current without inventing an approval or refusal outcome.
C256ball Current-Status Guardrail
Ballarat North/C256ball has passed its reserved March 2026 SAC hearing window, but the corpus does not contain a SAC report, Ministerial decision, approved amendment or gazettal record. The defensible current status is post-exhibition/post-hearing-window with outcome not in corpus. (Source: vpa-ballarat-north-psp-draft-amendment-c256ball-explanatory-report-public-consultation.txt; Source: Ballarat-North-PSP-Draft-Amendment-C256ball-Explanatory-Report-Public-Consultation.pdf)