Hi Brad
We received a similar application (about 5yrs ago) from a PBI (not Anglicare) and only granted an exemption on the part that is used for a benevolent purpose.
In our matter the circumstances are, 250 non-benevolent units + 50 high-care (including palliative and dementia ward in a separate building) all on the same parcel of land. We applied to the VG for a separate valuation under Section 556(3) and granted exemption on the high-care only.
If the PBI challenged I think we would need to reassess our position as precedent from the Community Housing v Clarence case provides that any land belonging to a PBI is for the purposes and therefore exempt.
No doubt you have established that the social housing is all leased at reduced market rent, affordable housing is not exempt.
Hope this is helpful, happy to discuss further in necessary.
Regards,
Andrew