---
title: "Initial Findings Report — Lot 2226, Stage 2C, 913 Appin Road, Gilead (Full Text)"
project: "R2G-2026-013"
client: "Simon Canov"
site: "Lot 2226, Stage 2C, 913 Appin Road, Gilead NSW 2560"
requested_scope: "8 x Two-Storey Multi-Dwelling Units, Class 1a"
report_date: "2026-08-06"
prepared_by: "R2G Projects Pty Ltd"
status: "Preliminary — not conclusive, see §06"
related_deliverable: "web/R2G_Initial_Findings_Report_Lot2226_lite.html (illustrated version); web/Lot 2226, Stage 2C, 913 Appin Road, Gilead — Initial Findings Report.html (full); update web/ HTML when this report changes"
---

# Initial Findings Report — Full Text

**Lot 2226, Stage 2C, 913 Appin Road, Gilead NSW 2560**
Lot 2226 in an unregistered Deposited Plan (Stage 2C, Figtree Hill) · Campbelltown City Council
Requested: 8 x Two-Storey Multi-Dwelling Units (Townhouse/Villa, Class 1a)
Initial Findings — Requested Yield Tested Against Title, Subdivision & Building Envelope Records

**Prepared by:** R2G Projects Pty Ltd · **Report date:** 6 August 2026 · **Status:** Preliminary — not conclusive, see §06

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## 01 · Project Description — What This Report Covers

The owner has asked R2G to test the feasibility of 8 x two-storey multi-dwelling units (townhouse/villa, Class 1a) on Lot 2226, Stage 2C, 913 Appin Road, Gilead — the yield and project type set out in R2G's Desktop Feasibility Offer FP‑2026‑013 (5 July 2026). This report is not that feasibility deliverable itself; it is the initial findings check against the property records actually in hand right now — the Contract of Sale bundle, the Stage 2C subdivision plan, and the title-registered Building Envelope Plan — before any further design or fee spend proceeds. It states what those documents show about the requested yield, what they show about a fallback yield, and what remains unconfirmed. It does not determine a final approval outcome.

**Key facts**

| Field | Value |
|---|---|
| Project (as requested) | 8 x Multi-Dwelling Units — yield not yet confirmed achievable, see §06 |
| Address | Lot 2226, Stage 2C, 913 Appin Road, Gilead NSW 2560 |
| Legal Description | Lot 2226 in an unregistered DP; title ref (parent) part folio 3/1240836 |
| Council | Campbelltown City Council |
| Zone | R2 Low Density Residential — indicated, not yet lot-specific-certified, see §04 |
| Lot Area | 718.8 m² (Stage 2C subdivision plan / Building Envelope Plan) |
| Frontage | Corner lot — approx. 23.92 m & 24.295 m, two road frontages + 5.235 m corner splay |
| Approval Pathway | Preliminary — not conclusive; requested yield unconfirmed, fallback ≤2 dwellings indicated |

**Provenance of the information in this report**

Two distinct sources feed every R2G initial findings report, and they carry different obligations. Stating this distinction up front avoids documents the client already owns being written up as if R2G needed to "obtain" them, and avoids R2G-commissioned work being mistaken for something the client already had.

- **Client-Supplied:** The Contract of Sale bundle for Lot 2226, Stage 2C (contract date 14 June 2025), including the Section 10.7 planning certificate (Application No. 202502439, issued 11 June 2025), the Deposited Plan Instrument sheets, the Figtree Hill Design Essentials, the Bushfire Assessment Report reference, and the Biodiversity Certification Agreement annexures — supplied by the client from their purchase file. Also client-supplied: R2G's own Desktop Feasibility Offer FP‑2026‑013, which is the source of the requested 8-unit yield tested in this report.
- **R2G-Commissioned:** None at this stage. No site survey, updated planning certificate, or bushfire/geotechnical assessment has yet been separately commissioned by R2G. This report is a desktop read of the client-supplied bundle and the publicly available Stage 2C subdivision and Building Envelope Plan drawings prepared by LTS (surveyor) and Arcadis (for Stockland/SRCP) — nothing more.

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## 02 · Client-Supplied Source Documents

Five documents from the client-supplied Contract of Sale bundle and the R2G engagement file were available for this review. Every finding below traces to one of these five; nothing has been assumed beyond what they actually state.

**1. Section 10.7 Planning Certificate** — Application No. 202502439 · Issued 11 June 2025 · Campbelltown City Council
Issued for "Lot 3 Appin Road, Gilead" (Lot 3 DP 1240836) — the broader parent parcel, not a lot-specific certificate for Lot 2226, which does not yet exist as a separate registered title. States that R2 Low Density Residential, RE1 Public Recreation, SP2 Infrastructure and R3 Medium Density Residential all apply somewhere across the parent land under Campbelltown LEP 2015; confirms bush fire prone land, a proclaimed Mine Subsidence District, and flood-related development controls apply to the certificate land; states Council has insufficient information to determine contamination status; and lists the Campbelltown (Sustainable City) DCP 2015 as the applicable DCP.

**2. Deposited Plan Instrument — Sheet 9 of 20, Restriction (O2C) (Design) & "Duplex Lot" Definition** — Plan of Subdivision of Lot 2000 in DP1291134 etc. · Stage 2C
Registers Restriction on the Use of Land (O2C) (Design) numbered 3, which otherwise ties every dwelling to the Figtree Hill Design Essentials, but expressly defines **"Duplex Lot"** as each of Lots 2222, 2225, **2226**, 2288 and 2289, and exempts Duplex Lots from the restriction's usual subdivision constraint. This is the title-level source for treating Lot 2226 as a designated two-dwelling (duplex) allotment rather than a general single-dwelling lot.

**3. Plan of Proposed Subdivision — Stage 2C** — Ref. 43240 059SUB‑2C, Sheets 1–2 of 2 · Dated 15 September 2022 (Revision J, 11 April 2025) · LTS (Registered Surveyor NSW), Client: SRCP (Figtree Hill) Pty Ltd
Shows Lot 2226 at 718.8 m², a corner allotment within the 99-lot Stage 2C release (94 residential + 5 residue lots), with boundary dimensions of 23.99 m, 24.295 m, 23.92 m, a 5.235 m corner splay, and a 28 m party boundary to Lot 2227. Confirms Lot 2226 sits at the edge of Stage 2C adjoining existing residential subdivision to the north-west.

**4. Figtree Hill Stage 2C — Building Envelope Plan** — Drawing FTH‑2C‑CC‑AAP‑CV‑SKT‑0001, Issue 10 · Dated 6 May 2025 · Arcadis Australia Pacific Pty Ltd for Stockland — status "PRELIMINARY — NOT TO BE USED FOR CONSTRUCTION"
This is the plan given legal force by title Restriction (BEP) numbered 5, which prohibits development on Lot 2226 unless it accords with this drawing. It flags Lot 2226 with the "Potential Dual Occupancy Development" triangle symbol — defined in the plan's own legend as a development resulting in **two dwellings on a single allotment of land, subject to Campbelltown Council approval**, with driveway locations not fixed. The drawing does not show, and gives no indication of contemplating, an 8-unit configuration on this lot.

**5. R2G Desktop Feasibility Offer** — FP‑2026‑013 V1 · Dated 5 July 2026 · R2G Projects Pty Ltd
The source of the requested 8-unit yield and the project parameters tested in this report. Notes the site's parent-parcel zoning as "RU2 Rural Landscape — subject to post-subdivision confirmation." This is inconsistent with the Section 10.7 certificate, which does not list RU2 for the certificate land at all — see the correction note in §04.

> **Currency check — non-negotiable:** The Section 10.7 certificate was issued 11 June 2025 — 14 months old as at this report's date (6 August 2026), and it was never lot-specific to begin with (it covers the whole Lot 3 DP 1240836 parent parcel, which spans four different zones across multiple stages). Every zoning, bushfire, flood, and mine-subsidence finding drawn from it in this report is a parent-parcel indication only. It must be replaced with a fresh, lot-specific certificate once Lot 2226 is a registered title before any of these findings can be relied upon for design or lodgement.

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## 03 · Site Survey — No Site Survey Has Been Commissioned

No detail or contour survey of Lot 2226 has been commissioned by R2G, or supplied by the client, for this engagement. Everything below is read off the Stage 2C subdivision plan and Building Envelope Plan — both preliminary, both marked "not to be used for construction" by their own authors — cross-checked against the title restrictions in the Contract of Sale bundle. Until a survey is commissioned, every siting finding in this report is unsurveyed and indicative only.

**What the plan documents establish (unsurveyed)**

| Item | Detail |
|---|---|
| Lot area | 718.8 m² — consistent across the subdivision plan and the Building Envelope Plan. Not survey-verified. |
| Existing structures | None shown or referenced — Lot 2226 is vacant, unregistered subdivision land. |
| Ground levels | Design contours are shown on the Building Envelope Plan but have not been independently checked; no benchmark or datum reduction has been sighted for Lot 2226 specifically. |
| Registered easements / restrictions | Per the Deposited Plan Instrument: Restriction (N2C) (Filling), Restriction (L2C) (BAL — construction to AS3959 and the Stage 2C Bushfire Assessment Report), Restriction (O2C) (Design — exempted for Lot 2226 as a Duplex Lot), and Restriction (BEP) numbered 5 (development must accord with Drawing FTH‑2C‑CC‑AAP‑CV‑SKT‑0001). Lot 2226 is annotated (N2C)(L2C) on the subdivision plan. No easement for drainage (D2C) is shown crossing Lot 2226 itself on the sighted extract. |
| Benchmark | Not established for Lot 2226 — no R2G-commissioned survey exists. |

> **Corner lot condition:** Lot 2226 reads as a corner allotment on the subdivision plan, with frontages to two proposed roads joined by a 5.235 m splay. The Building Envelope Plan's Setbacks Plan Legend applies additional corner-lot requirements (secondary street setback, corner lot articulation, corner lot fencing) that a mid-block lot would not attract — this has not yet been checked against a specific dwelling design because none has been prepared.

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## 04 · Statutory Planning Context (From the Section 10.7 Certificate — Parent Parcel)

| Control | Applies to site |
|---|---|
| Height of buildings | Not sighted — no Height of Buildings clause/map extract was included in the certificate's attachments. Confirm separately. |
| Applicable DCP | Campbelltown (Sustainable City) DCP 2015 (certificate Item 1(3)). Specific numeric standards for the achievable dwelling type not yet sighted. |
| Heritage | Certificate Item 2(g): no item of environmental heritage on the certificate land. A general note flags possible unmapped Aboriginal heritage on the AHIMS register (not site-specific). |
| Bushfire | Certificate Item 11: all of the certificate land is mapped bush fire prone land. Lot-specific BAL rating not confirmed — see §03 and §07. |
| Flood | Certificate Item 9: land within the flood planning area, subject to flood-related development controls. Lot-specific extent for Lot 2226 not confirmed. |
| Mine subsidence | Certificate Item 13: certificate land is within a proclaimed Mine Subsidence District — Subsidence Advisory NSW approval required for subdivision and building. |
| Contamination | Certificate Item 10: Council records are insufficient to determine whether the land is contaminated. |
| Contributions | Campbelltown Local Infrastructure Contributions Plan 2018 (Amendment 1) and a s7.4 Voluntary Planning Agreement for the Mount Gilead site both apply (certificate Item 3). The State "Housing and Productivity Contribution" may also apply. |
| Key SEPPs engaged | SEPP (Biodiversity and Conservation) 2021; SEPP (Exempt and Complying Development Codes) 2008; SEPP (BASIX) 2004; SEPP (Housing) 2021; SEPP 65 — as listed in the certificate. The certificate land is separately confirmed (elsewhere in the Contract of Sale bundle) as covered by the Mt Gilead Biodiversity Certification Agreement, meaning biodiversity impact is not a separate consent consideration for this DA site. |

> **Note on zoning — correction:** R2G's own Desktop Feasibility Offer (FP‑2026‑013) records the parent parcel zoning as "RU2 Rural Landscape — subject to post-subdivision confirmation." The Section 10.7 certificate does not list RU2 anywhere for this land; it lists R2 Low Density Residential, RE1 Public Recreation, SP2 Infrastructure (Classified Road) and R3 Medium Density Residential. Separately, the Biodiversity Certification Agreement background report in the same Contract of Sale bundle states the residential subdivision DA land is zoned R2 Low Density Residential and RE1 Public Recreation. Between these, the certificate and the DA-zoning statement agree and both supersede the Feasibility Offer's RU2 reference, which appears to be stale or generic wording. On balance, R2 Low Density Residential is the better-supported indication for the Stage 2C residential lots, including Lot 2226 — but this is not the same as a lot-specific certificate naming Lot 2226 by its own zone, which does not yet exist.

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## 05 · Proposed Development — Requested Yield vs. What the Records Indicate Is Achievable

Neither side of this comparison is a compliance-checked design. The achievable-yield side reflects the Building Envelope Plan's own dual-occupancy notation, not a drawn concept — no design has been prepared for either scenario.

**Requested — 8 Multi-Dwelling Units** *(no concept drawing has been supplied or prepared for this scenario)*
- Site area: 718.8 m²
- Implied area per dwelling: ≈89.8 m² / dwelling
- Land use permissibility: Multi dwelling housing is not a permitted use in Zone R2 (Campbelltown LEP 2015 land use table) — the zone best indicated for this lot
- **Blocking:** prohibited use if R2 applies (§07); BEP restriction (cl.5) does not show this configuration on the lot regardless of zone.

**Achievable per Title & BEP — Dual Occupancy (2 Dwellings)**
- Site area: 718.8 m²
- Title designation: "Duplex Lot" (DP Instrument, Sheet 9/20)
- BEP notation: "Potential Dual Occupancy Development" — 2 dwellings, subject to Council approval
- Zone-clause fit: 718.8 m² clears the 700 m² cl.4.1C minimum qualifying site area for a semi-detached dwelling in Zone R2 by 18.8 m²
- **Open item:** this is a title/BEP designation, not a Council-approved yield — dwelling count and design still require consent, and zone is not yet lot-certified.

> **Why the 700 m² figure matters:** Lot 2226's 718.8 m² area is not a coincidence relative to the requested yield question. Clause 4.1C of Campbelltown LEP 2015 sets 700 m² as the minimum qualifying site area for a semi-detached dwelling in Zone R2 — a threshold this lot clears by only 18.8 m². Combined with the title's own "Duplex Lot" label and the Building Envelope Plan's dual-occupancy flag, three independent, differently-sourced records point the same direction: toward a lot sized and designated for two dwellings, not eight. That convergence is a strong indicator, not a Council determination — see §06.

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## 06 · Why This Report Is Not Conclusive — Two Structural Gaps Between "Indicated" and "Confirmed"

This report leans toward a fallback finding — that Lot 2226 is designed and titled for a maximum of two dwellings, not the requested eight. That lean is well-supported by three independent sources (§05). It is still not a confirmed position, for two structural reasons.

**1. Lot 2226 has no lot-specific planning certificate yet.** Lot 2226 exists only in an unregistered deposited plan. Every zoning, bushfire, flood, mine-subsidence and heritage finding in this report is drawn from a Section 10.7 certificate issued against the much larger parent parcel (Lot 3 DP 1240836), which spans four different zones across multiple development stages. Nothing in the sighted documents certifies, lot by lot, which of those zones actually lands on Lot 2226 once it is registered.
> ⚠ The R2 Low Density Residential lean in §04 is the best-supported reading of the parent-parcel certificate and the DA-zoning statement together — it is not a substitute for a fresh, lot-specific certificate obtained once Lot 2226 is a registered title. If the fallback 2-dwelling finding in §05 is to be relied on for design or lodgement, this certificate must be obtained first.

**2. The Building Envelope Plan is a title-registered constraint, not a Council-approved yield.** The BEP's "Potential Dual Occupancy Development" flag on Lot 2226 is Stockland's own developer notation, given legal force on title by Restriction (BEP) numbered 5. It states the two-dwelling outcome is possible and is "subject to Campbelltown Council approval" in the plan's own words — it is not a development consent, and it does not itself rule out a different configuration Council might approve if properly tested.
> ⚠ This report's lean toward a 2-dwelling fallback (not 8) is contingent on that BEP notation and the Duplex Lot title designation both holding once tested with Council — a pre-DA enquiry or written Council confirmation has not yet been sought (see §08, item 3).

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## 07 · Gating Requirements — Campbelltown LEP 2015 & Title Restrictions Compliance Check

The approval pathway (DA or CDC) for either yield has not been determined, so this checks the gating requirements common to any pathway — permissible use, minimum lot size, and the title restrictions specific to this lot — rather than a single code's numeric development standards.

| Standard | Requirement | Site Condition | Status |
|---|---|---|---|
| Permitted land use — Multi dwelling housing (8 units, as requested) | Permitted with consent in Zone R3 Medium Density Residential only; not listed as permitted in Zone R2 | R2 Low Density Residential is the better-supported zone indication for this lot (§04) — not yet lot-certified | **Blocking item** |
| Minimum qualifying site area — semi-detached dwelling, cl.4.1C (Zone R2) | 700 m² minimum | 718.8 m² per subdivision plan / BEP — clears the threshold by 18.8 m² | **Passes** |
| Title Restriction (O2C) (Design) | Dwelling must comply with Figtree Hill Design Essentials, unless the lot is exempted as a Duplex Lot | Lot 2226 is named as a Duplex Lot and is exempted from this restriction's subdivision constraint | Confirm |
| Title Restriction (BEP) numbered 5 | No development except in accordance with Drawing FTH‑2C‑CC‑AAP‑CV‑SKT‑0001 | Drawing shows only a 2-dwelling "potential dual occupancy" notation — no 8-unit configuration shown | **Blocking item** |
| Corner lot provisions (Setbacks Plan Legend) | Secondary street setback ≥3 m; corner lot articulation and fencing required | Lot 2226 appears to be a corner allotment — not yet checked against a specific design | Confirm |
| Bushfire construction standard (Restriction L2C) | Construction to AS3959‑2009 and the Stage 2C Bush Fire Assessment Report (Ref. 220989C, 25 Mar 2024, DA 41/2023/DA‑SW) | Certificate confirms parent parcel is bush fire prone land; lot-specific BAL rating not sighted | Confirm |
| Mine subsidence clearance | Subsidence Advisory NSW approval required in a proclaimed Mine Subsidence District | Parent parcel confirmed within district; lot-specific clearance not sighted | Confirm |
| Height of buildings / FSR | Campbelltown LEP 2015 cl.4.3 (height) / applicable FSR, if any | Not included in the certificate's Attachment 2 extracts sighted — no figure obtained | Confirm |

> **Two blocking items identified.** The requested 8-unit yield fails on permitted land use if the R2 zone indication is confirmed, and separately fails against the title-registered Building Envelope Plan regardless of zone outcome — either one is enough to hold the requested yield unconfirmed. The five "confirm" items do not currently block anything but must be resolved before the fallback 2-dwelling yield can be relied upon either.

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## 08 · Path to a Confirmed Pathway (Before Any Option Is Relied Upon)

Ordered by dependency — later items assume the earlier ones have resolved. **High** means it blocks later stages; **Medium** is needed before lodgement but doesn't block the comparison itself.

**Stage 1 — Verify the Lot Itself**
1. *(High)* Obtain a fresh, lot-specific Section 10.7 planning certificate for Lot 2226 once its plan of subdivision is registered. — blocks confirming zone, bushfire, flood & mine subsidence status.
2. *(High)* Confirm Lot 2226's current registration status and obtain the registered/current title once available. — blocks item 1 and all downstream design work — **Client-side**.
3. *(High)* Seek written confirmation from Campbelltown Council (pre-DA enquiry) on whether the Duplex Lot / BEP notation caps consent at 2 dwellings, and whether 8 multi-dwelling units is precluded outright. — blocks the yield question at the centre of this report — **R2G-side**.

**Stage 2 — Feasibility for the Achievable Yield**
4. *(Medium)* Commission a detail & level survey of Lot 2226. — **R2G-commissioned**.
5. *(Medium)* Obtain and review the full Bush Fire Assessment Report (Ref. 220989C) to confirm the BAL rating and Inner Protection Area applicable to Lot 2226. — **R2G-side**.
6. *(Medium)* Confirm Campbelltown DCP 2015 numeric standards applicable to the achievable dwelling type (setbacks, POS, parking) beyond the BEP. — **R2G-side**.

**Stage 3 — Pathway Decision**
7. *(High)* Determine and confirm the approval pathway (CDC vs DA) for the achievable 2-dwelling outcome. — gates lodgement — **R2G-side / Certifier-set**.

**Confirmed Pathway — Not Yet Reached.** Achievable yield and approval pathway remain to be confirmed by Council/certifier and a lot-specific planning certificate.

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## 09 · Legal Disclaimers — Terms of Use

This report is provided for **information only** and does not constitute:
- A development approval or consent of any kind
- A Statement of Environmental Effects (SoEE)
- A binding determination or direction by R2G Projects Pty Ltd
- Professional advice upon which the client may rely for any purpose other than general information

The client acknowledges and agrees that:
- Final plans must be assessed and determined by the relevant certifying authority
- This report does not guarantee any particular outcome from Council or a private certifier
- All findings in this report are preliminary and based on information available as at the report date
- Circumstances, planning controls, and site conditions may change and should be independently verified
- The client is responsible for obtaining a current, lot-specific Section 10.7 planning certificate for Lot 2226 once it is registered, and for supplying any documents referenced but not yet located by R2G
- R2G Projects Pty Ltd accepts no liability for any loss, damage, cost, or expense arising from reliance on this report
- This report is intended for the named client's internal use and may not be reproduced or distributed to third parties without R2G Projects Pty Ltd's written consent

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## 10 · Next Steps — Path Forward

In the order they would actually happen. This report does not include a fee schedule for these steps — that is a separate, per-job decision for R2G and the client to confirm before it is added.

1. Lodge a pre‑DA enquiry or written request to Campbelltown Council confirming the maximum dwelling yield achievable on Lot 2226 given its Duplex Lot title designation and BEP dual-occupancy notation. — **R2G-side**
2. Client to confirm Lot 2226's current registration status, or provide the most recent title search if registration has progressed since the Contract of Sale. — **Client-side**
3. Obtain a fresh, lot-specific Section 10.7 planning certificate for Lot 2226 once registered. — **Client-side / R2G-side**
4. Source and review the full Bush Fire Assessment Report (Ref. 220989C) referenced on title, to confirm the BAL rating applicable to Lot 2226. — **R2G-side**
5. Client to confirm whether to proceed on the achievable dual-occupancy (2-dwelling) basis, given the requested 8-unit yield appears precluded by both zone and the title-registered Building Envelope Plan. — **Client-side**

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*R2G Projects Pty Ltd — Information only, not a binding approval or direction.*
*This is the full-text markdown transcript of the Initial Findings Report. The illustrated HTML for display is in `web/` (`R2G_Initial_Findings_Report_Lot2226_lite.html` and the full Lot 2226 HTML). When this markdown is updated, refresh those HTML files so the dashboard / website stay in sync.*