BHPA response to Local Area Plan Scenarios Paper

This is the response from the Brown Hill Progress Association to the Brown Hill Local Area Plan Scenarios Paper. Due to COVID pandemic the plan has been put on hold. We will keep you posted on progress when Council resumes consultations.

If you have any questions or comments please get in touch with the Brown Hill Progress Association, at contact us.

Brown Hill Progress Association Response to Local Area Plan Scenarios Paper

The Brown Hill Progress Association is pleased to have the opportunity to respond to the City of Ballarat’s future growth scenarios paper, including a summary document, together with the background report and technical appendices for the development of the Brown Hill Local Area Plan.

After discussion and perusal of the documents we present the following comments for your consideration for the next stage of the Brown Hill Local Area Plan.

Please note that the following comments do not cover every aspect in the documents but only key issues and concerns that we believe are of fundamental importance to the future of our community. These relate to:

  • Road issues
  • Capacity of infrastructure and services
  • Bushfire and other emergency risks
  • Public realm/commercial growth/community facilities
  • Development scenarios

Road issues (4.9 infrastructure report)

The report analysis concerning Brown Hill roads does not take into account that Brown Hill is a major entry point for communities north of Ballarat and travellers off the freeway it is not just“local” traffic. The following intersections are a major concern in regards to the safety of residents especially children and the flow of traffic:

  • Water and Victoria Streets
  • Humffray and Water Streets
  • Springs and Daylesford Roads
  • Western Freeway and Water Street interchange
  • Brewery Tap Road and freeway access

What is missing in the study area documents is the context for these particular intersections. For example regarding the Water and Victoria Streets intersection:

  • Two schools are in close proximity – Caledonian Primary School and Woodman’s Hill Secondary College;
  • Scott’s Pde that feeds into the intersection is used as a major through road to Ballarat’s northern suburbs and vice a versa;
  • Major school bus interchange along Old Melbourne Road;
  • No consideration given to capacity of the intersection to manage an emergency scenario/situation either involving safe passage of residents, including those further north of Brown Hill and the movement of emergency vehicles.

Solution: It is a conundrum that will require a significant degree of lateral thinking to ensure ALL aspects of the intersection’s shortcomings are addressed. As it will require major capital works and discussion between council; VicRoads and VLine, we accept that it would not be an easy or quickfix and we would prefer no piecemeal attempts that would more than likely exacerbate the problem and waste time and money.

PRIORITIES (Water and Victoria Streets intersection):

  • Instigate a comprehensive study to develop an intersection design that address the above issues and involves community members throughout the process. Ensure that resources are allocated, at least tentatively, for future capital works;
  • In the short term council to discuss with community members how traffic management strategies may help alleviate the most pressing concern such as children's safety

Humffray and Water Streets intersection: Counting the number of vehicles does not account for the numerous near misses at this intersection.


  • Introduce traffic management solutions for this intersection, e.g. slow the traffic with reduced speed limit, round-about.
  • This intersection is NOT suitable for a Town Square or Plaza, use this “space” to improve the safety of the intersection and shop accessibility (increased parking?)

Springs and Daylesford Roads intersection: This intersection which also incorporates Ditchfield Lane is again problematic especially with the expected growth of emerging Brown Hill and the needs of safe exiting during emergencies.

  • This is not the intersection to introduce a “small commercial development”;
  • The proposed orbital or interconnected road network does not address the existing problem that all traffic will still funnel into Springs Rd and the intersection with Daylesford Road


  • Along with the listed orbital road upgrade there needs to be at least two new roads which connect Hillview Drive with Daylesford Road so there would be at least three exits for residents to take pressure off the intersection.
  • It should also be noted that every development should have at least two exit points.

Western Freeway and Water Street interchange: There is concern that traffic entering Water St from both directions fail to understand that they are entering a suburban area.


  • Install stop signs at both exit points of freeway. This would also be a safety measure for walkers and cyclists, using the underpass;
  • Any addition to footpaths/shared or otherwise at the underpass need to be properly integrated with the rest of the footpath network, with the issues of safety addressed
  • A traffic management strategy to be developed and implemented that incorporates Springs Road; freeway interchange; Water & Humffray Sts intersection, shopping centre, and possibly include hall/pool/reserve, as one precinct; consider installing pedestrian crossings in key areas – shops; schools; hall/pool/reserve; a 40km zone

Brewery Tap Road and freeway access (note: there was no VicRoads Western Highway Alignment appendix attached): This is another intersection of concern and considering that the proposal to remodel this intersection is now five years old it is disappointing that efforts to implement this remodelling have not been done.

Civil infrastructure and services (4.8 infrastructure report)

Stormwater/potable water/sewage infrastructure

From the report there appears a strong indication that the water infrastructure/delivery systems are at capacity for the CURRENT level of housing. i.e.If further intensive land development occurs in the upstream catchment, a stormwater management strategy will be required to cater for the increased flow. A future Drainage Scheme for Emerging Brown Hill is essential.

  • The existing system is at the limit of its capacity to supply Peak Day and upgrades are required.
  • ‘Level of service’ issues currently exist in eastern Ballarat at the extremities
  • The existing network requires upgrades to cater for existing and future demands.
  • Continuing development in emerging Ballarat will continue to impact delivery of potable water without major upgrades.
  • There are existing network capacity constraints for both sewerage and potable water systems within the Brown Hill area.
  • There is currently no available wet weather capacity in the trunk sewerage network and also with significant growth in Brown Hill there may also be dry weather capacity issues for these trunk sewers also.

PRIORITIES: Until the following has been addressed further approval of residential development to be restricted to ensure that there is sufficient capacity of the infrastructure and services to be able to accommodate any further expansion. This is to apply to both the established and emerging areas of Brown Hill.

Council to actively assist Central Highlands Water to:

  • Upgrade infrastructure/system to ensure greater capacity to supply peak day potable water requirements for future growth;
  • Develop and implement an updated Drainage Scheme for emerging Brown Hill
  • Address the current “level of service” issues
  • Increase capacity of the trunk sewerage network for both wet and dry weather capacity
  • Such upgrades need to also consider the increased requirements of the system to accommodate for any extreme event that would impact on the existing day to day infrastructure.

Electricity- Transmission network

Upgrade options may require creating new transmission line capacity (additional circuits) which would require either land acquisition or new easements (such as easement widening) through the Brown Hill area.

QUESTION: Has this been taken into account when approving further developments?


There is no mention in the report of the wide spread lack of mobile phone coverage in the emerging Brown Hill area. This could have major ramifications in a emergency situation.

PRIORITY: Council to encourage telecommunication providers to eliminate mobile black spots as soon as possible.

Bushfire and other emergency risks (4.5 of Infrastructure report)

As almost the entire study area falls within the bush fire prone area. Increased development in this area heightens the risk to life and property in this heavily vegetated area. Additionally there is a conflict between bushfire controls and habitat objectives (e.g.. Protection of koala habitat under the Environmental Significance Overlay – Schedule 5) The scenario and other documents provided to the community, at this stage, do not provide any recommendations/options regarding the risk or conflict.

Planners and consultants need to be aware that in an emergency situation Springs Road and Daylesford Road would become major thoroughfares for residents BEYOND the suburb of Brown Hill making their way to the CBD and also they are the only major roads for emergency vehicles exiting to the north.


  • Include meaningful recommendations in relation to site design and road layouts in the context of lowering the bushfire risk to residents especially in regard to ease of evacuation and access in emergency situations;
  • Prepare a Brown Hill Evacuation Plan and identify “places of last resort” – including walking and vehicle egress this side of the railway line and also preferably one north of the freeway;
  • Along with the listed orbital road upgrade there needs to be at least two new roads which connect Hillview Drive with Daylesford Road so there would be at least three exits for residents to take pressure off the Springs Rd intersection.
  • Resolve the conflict between bushfire and environmental overlays as quickly as possible

Public realm/commercial growth/community facilities

Create an integrated active transportation network (opportunity 2)


Water St- a grand boulevard: That’s OK but Water St has a road reserve that could easily accommodate a SEPARATE and SHARED cycling / walking lane. To make it a grand boulevard it requires a dedicated tree scape and well maintained flower beds

Multi path under freeway: an emphasis is required on safety – safety barriers? There should only be 2 lanes of traffic (3 is shown in image)

Multi use path along Springs Rd: DISAGREE It is difficult to see how such a path can be accommodated. This is an 80km speed limit area and there are major safety concerns. It would have to be separate from vehicle lanes.

GREATER PRIORITY - Pedestrian connections:

  • Footpaths to be provided on both sides of all new residential streets;
  • Footpaths to be constructed on both sides of all existing streets with a classification of a collector street or higher;
  • Any existing streets used by buses to be provided with pedestrian footpaths on both sides of the street, to encourage public transport usage

Add and improve bus stops: DISAGREE The current Brown Hill bus service and route is inadequate and actively discourages further public use. Adding and improving bus stops will NOT improve the situation.

  • To encourage any uptake of public transport – smaller buses (could navigate the narrow streets more easily) with a direct route to CBD/station to be established;
  • Council needs to be proactive in advocating for residents to change the meandering bus route that afflicts the Brown Hill suburb
  • A staged increase of servicing existing residential areas to a level that ensures current metropolitan standards (400m from public transport)
  • Remove bus route from Thompson St – this is the school street and narrow, big buses are a safety issue and are difficult to manoeuvre
  • Route expansion opportunities may include:
  • Melbourne Road and Ryan Street to the south-east of Water Street;
  • Gracefield Road, Brewery Tap Road and Daylesford Road; and
  • Hillview Road, Springs Road (with a new connection between these)

Strengthen the Humffray St Centre (opportunity 4)


  • Consider a town square for Brown Hill in underutilised right of way: DISAGREE STRONGLY this is not the place for such a public space. The town “square” or centre is already evolving at the Brown Hill Reserve and this is what needs developing. More facilities for children & teenagers would be useful. Some ideas to consider: Skate Park; half basketball court; solar lighting in reserve and along walking tracks; additional public toilets; drinking taps; appropriate shading for play ground; upgrading pool and installing solar heating
  • Council to pro-actively support an increased multi-use of the cricket ground
  • Improve public realm amenity with landscaping: always a nice touch and should be an integrated part of delivering essential basics. e.g. beautifying bus stops does not encourage bus usage when the bus service is broken. Adding a statue does not protect people from the heat.
  • Improving the issues of the Humffray/Water St intersection will improve the amenity of our existing shopping centre;Please note that the Post Office is not “beloved” but a much needed practical service not only for Brown Hill residents but for the communities north of Ballarat.

Capacity for new local businesses or commercial/industrial concerns (4.6 Economic assessment)

After reviewing this section of the Assessment Report it is accepted that an increase of the commercial sector for Brown Hill is limited by location and size of local population.

Other than council facilitating, where possible, the establishment of businesses in the area we would like to put forward the possibility of establishing a small but diverse Health Hub in Brown Hill. There are some larger blocks of commercial zoning along Water Street that may be suitable or even the right hand side of Daylesford Road just past the freeway where the CHW pump station is located, or council may have other suggestions – Daylesford Road and Brewery Tap Rd?

Such a Hub would not only service the local area but the wider Ballarat community. Being on the“edge” of town only makes it far more accessible by using the bypass.

PRIORITY: Council to investigate the feasibility of establishing a multi-use Health Hub for Brown Hill area

Strengthen and enhance the waterways in Brown Hill (Opportunity 1 & 4.10.2)

Create a connected open space ... to engage in the natural environment: This is admirable but its value would be diluted or negated by the back drop of the many areas that are heavily overrun by invasive woody plants and noxious weeds, both in the creek beds and banks. This is a major issue for our waterways. Having such occurrences not only smothers any natural vegetation but also presents a heightened fire risk to Brown Hill. Again it is an attempt to add the gloss to an area without fixing the fundamental basics first.

Regarding the opportunities listed at 4.10.2: These are all broad brush/ generic opportunities taken from particular strategies already prepared. They are not localised – i.e. they do not highlight particular areas of priority or concern within the Brown Hill area or how to specifically deal with them.

PRIORITY: Develop a comprehensive management plan for weed management and eradication for Brown Hill waterways with an implementation plan and corresponding resource allocation to ensure the continual increase of weed free areas of our waterways in an ongoing and systematic way; progress to be reported to the Brown Hill community on a yearly basis.

Development scenarios

The draft Scenarios Paper provided three scenarios – status quo; growth and balanced approach.

The status quo and growth scenarios are REJECTED.

The Balanced Approach is far more accommodating to the aspirations of residents BUT there are key concerns that the presented model does not address.

When looking at the map for the Balanced Approach it is quite alarming to note the extent of the“red” areas in the established section (infill development opportunities). Considering that the majority of these sites will be at an increased density than the current housing stock there would be a doubling or more of the population in this sector plus an increase in land covered by concrete, as most battleaxe blocks already are. There could be a tripling of vehicles using our feeder roads (1 large block 2 cars; 1 battleaxe development of even 4 dwellings can increase that to 6 to 8). It would place further pressure on the infrastructure restraints that have already been identified.

If all such infill occurs this would decrease the capacity to increase canopy cover for the city (by its very nature concrete and dwelling are the dominant feature). It would also erode any particular “country atmosphere” that the community would wish to retain. It is a dilemma that require some forethought.

PRIORITY:Council to provide guidelines to the community that address the above concerns.

The suggested orbital road network does not address the concerns of decreasing pressure on the Springs Rd intersection; does not provide other exists to Daylesford Rd and some subdivisions still only have 1 exit. PLEASE REFER TO ROAD ISSUES SECTION ABOVE

For the Balanced Approach to be acceptable it would need to address concerns and suggestions outlined above.

Other points to consider:

Farm zone to be retained;

In regard to houses being better sited to suit their locations such as on slopes or amongst vegetation we would also suggest that this planning process would be enhanced by council proactively promoting Environmentally Sustainable Design (ESD ) principles at the design phase of a development. This has been proven to be the best opportunity to make the greatest amount of difference in terms of sustainability for the least amount of cost.

Community vision

It is difficult to see how the “intrinsic qualities of Brown Hill such as the feeling of space, the country atmosphere and bushland backdrops ” can be “ever present and protected” without far more practical and proactive recommendations presented so far.

Natural Assets: would be lovely but is a CHW action

Development: Development tends to be a bare earth practice which does not lend itself to habitat qualities

Commercial: It has been demonstrated that there will be little commercial opportunities for Brown Hill. Ditto for Humffray St shops – emphasis should be on enhancing the Reserve; not “beloved PO; emphasis on possible Health Hub; what does “new land uses” mean? A childcare facility has been proposed.

Recreation: OK as it is but is just maintaining what is current

Walking & cycling: note comments above


The documents presented for comment have been hard going even for those who are very committed to the process. There is a lot of background that is not relevant to residents (put in an appendix); when an appendix was listed it was not attached; it was difficult to find the concrete suggestions to comment on; grand statements can be interpreted in many different ways – which is not helpful when trying to arrive at a general consensus of what something means; it would not be surprising if there is little response from the “public” - it can all get a bit too hard.