Minor Change Council Report 132006.1395.05

132006.1395.05 – minor chaNGE TO deVELOPMENT PERMIT FOR MATERIAL CHANGE OF USE – MULTIPLE DWELLING (10 UNITS) AT 142 NOOSA DRIVE, NOOSA HEADS

Document information

Author	Patrick Murphy, Coordinator Planning
Environment and Sustainable Development Department

Index	ECM/ Application/ 132006.1395.05

Attachments	1. 	Proposal Plans

APPLICATION DETAILS
Application No.	132006.1395.05
Development Approval	Development Permit For Material Change Of Use – Multiple Dwelling (10 Units)
Applicant	Royal Automobile Club of Victoria (RACV) LTD
Request Received On	12 August 2019

PROPERTY DETAILS
Property Address	142 Noosa Drive, Noosa Heads
RP Description	Lot 3 SP 126203
Land Area	5453m²
Existing Use of Land	Undeveloped land

STATUTORY DETAILS
SEQRP Designation	Urban Footprint
Locality	Noosa Heads
Zone	Semi-Attached Housing Open Space Conservation
Overlays	Biodiversity Overlay: Riparian Buffer and Environment Protection Area Natural Hazard Overlay: Flood Hazard Overlay, Bushfire and Acid Sulphate Soils
Assessment Type	Minor Change to Development Approval

RECOMMENDATION
That Council note the report by the Coordinator Panning to the Planning & Environment Committee Meeting dated 10 March 2020 regarding Application No. 132006.1395.05 for a minor change to an existing approval for Material Change Of Use – Multiple Dwelling (10 Units) situated at 142 Noosa Drive, Noosa Heads and:
A.	Refuse the change for the following reasons:
The proposal does not constitute a minor change as it would result in a substantially different development due to the application applying to a new parcel of land.
The proposal is contrary to schedule 11, part 2, section 7 of the Planning Regulation 2017 as the development is situated in a koala assessable development area and does not provide for habitat connectivity or safe koala movement.
The proposal is inconsistent with biodiversity assessment benchmarks (1), (2), (4) and (5) of Part E of the State Planning Policy as the development will adversely impact upon koala habitat and linkages, with koala populations recognised as being matters of both national and state environmental significance.
The proposal is inconsistent with water quality assessment benchmarks (1) and (2) of Part E of the State Planning Policy as the development has not adequately demonstrated that water quality objectives will be achieved.
The proposed development will adversely impact upon the site’s ecological values, including koala habitat and linkage for koala movement throughout the site contrary to Overall Outcomes 13.7.2a)i, 13.7.2a)iii, 13.7.2a)iv, 13.7.2b), 13.7.2c), 13.7.2d)i, 13.7.2d)vii, 13.7.2e), 13.7.2g), and Specific Outcomes O1a, O3, O4, O5, O7, O10, O11, O16, O17, O18a), O18b), O18e), O18h), O19b), O19c), O19g) and O19i) of the Biodiversity Overlay Code.
The proposed development is inconsistent with the Noosa Heads Locality Code as the proposal will adversely impact on the site’s environmental values contrary to Overall Outcome 9.7.2a)iv and Specific Outcomes O3 and O20.
The proposed Bushfire Management Plan proposes vegetation removal and management within a part of the site which is zoned Open Space Conservation and is intended to be protected and managed to the exclusion of development.
The proposed development is contrary to the Natural Hazards Overlay Code as bushfire mitigation measures do not avoid or minimise impacts on the natural environment and ecological processes.
The proposed development is contrary to the Water Sensitive Design Code as modelling for stormwater treatment has not included all relevant run-off areas.
Insufficient detail has been provided to demonstrate the extent and potential impact of the proposed height variation for the dwelling units.
The proposed development is contrary to the draft Noosa Plan provisions, which reinforce the current Noosa Plan’s requirements for an appropriate response to the site’s natural hazards and protection of the site’s environmental values including vegetation retention.
B.	Note the report is provided in accordance with Section 63(5) of the Planning Act 2016.

REPORT
PROPOSAL
The applicant seeks approval to change the existing development approval for a multiple dwelling of 10 units to address the issues raised by Council’s decision to refuse to extend the currency period of the approval.
On 20 August 2018 Council was notified that the applicant had lodged an appeal to the Planning and Environment Court seeking the Court extend the currency period. At the 20 September 2018 Ordinary Meeting it was resolved to defend the appeal.
Notably, the current court proceedings have been paused until the assessment of this application is finalised, which is required by 20 March 2020 by the Court. The original approval remains current until such time as the court decides the appeal.
The applicant has submitted revised plans of development and supporting reports in respect of koala habitat, bushfire and stormwater.
The revised site plan results in the location of the structures and roads being adjusted slightly from the existing approved layout with the applicant’s primary intent being to retain additional koala trees compared to the original layout.
The application also includes a request to amend, delete and include new conditions relating to stormwater and bushfire management.
In terms of the proposed changes the applicant advises:
The proposed development will either comply with or can be conditioned to comply with the following key development parameters under the Noosa Heads Locality Code. In summary, the proposed development:
complies with the maximum allowable population density of 40.54 persons with the maximum population density being 33 persons;
complies with the maximum allowable site cover of 40%, with the proposal having a site cover of 23%;
complies with the maximum allowable GFA this being 1,621.60m², with 1,600m² or 160m² per dwelling unit being proposed;
complies with the required building height of two storeys; and
complies with the minimum car parking requirements providing for 20 covered spaces and 4 visitor car parking spaces.
In relation to koala habitat, the arborist, terrestrial ecology and stormwater management reports propose:
39 of the 66 Eucalyptus robusta koala habitat trees within the construction area are to be removed;
21 Melaleuca quinquenervia koala habitat trees within the construction area are proposed to be removed;
The removal of weeds, especially the climbing vines currently impacting the Eucalyptus robusta on site should improve tree health over time;
Strategic planting of Eucalyptus robusta in identified replanting zones to provide some mitigation of the impact of the development for koalas and provide food and shelter for koalas using the site;
Additional planting in the road reserve adjacent to the disturbance area, to provide a significant mitigation of the impact of the development on the habitat connectivity of the site;
A reduction in building footprint;
Use of permeable pavement to assist with retention of koala habitat trees; and
Provision of re-planting off-site or a financial contribution for koala offsets

The proposed re-planting zones are identified in green in the following image:

Figure 1: Re-planting zones

The following images detail the revised site plan and provide a comparison of the approved and proposed building footprints. A locality plan is also provided. The proposal plans are included at Attachment 1.

Figure 2: Proposed Site Plan

Figure 3: Comparison of approved and proposed building footprints

Figure 4: Locality Plan
background
The original application for the multiple dwelling development was received by Council on 7 July 2006 requesting that Council assess the application against the Superseded Planning Scheme. Council agreed to this request as it was considered to be largely consistent with The Noosa Plan 2006 at the time. The application was publicly advertised in August & September 2007 and no submissions were received during the advertising period.
A Preliminary Approval for a Material Change of Use Multiple Dwellings (10 Units) was granted on 24 January 2008. The preliminary approval was issued for the subject site as the applicant had not submitted a Bushfire Risk Assessment or a Bushfire Management Plan for the development. A Development Permit was not issued at the time as the Bushfire Management Plan may have resulted in changes to the proposed development layout due to fire buffers.
Following representations, it was agreed to issue a Development Permit, accordingly a Negotiated Decision Notice was issued on 15 May 2008.
A minor change application was approved on 14 July 2008 which:
Changed conditions relating to land identified as Open Space; and
Deleted the requirement for a further Development Permit for Material Change of Use as a Bushfire Management Plan was provided.
The following image details the approved layout:

Figure 5: Approved development layout
In December 2011 an application was received to extend the relevant period of the development approval by a further 4 years until 16 May 2016. On 5 April 2012 Council refused the application as it was considered that the community would not be appropriately aware of the development given the lapse of time. It was also thought that submissions may arise from the adjoining development to the north in the event that a further or new development application was submitted. Council staff considered a 2 year extension would be reasonable however, the applicant would not accept this timeframe.
The applicant appealed Council’s decision in the Planning and Environment Court. On 5 July 2013 the Sunshine Coast Council settled the appeal and agreed to extend the relevant period until 15 May 2016.
A further application to extend the currency period by 2 years was received on 22 December 2015. The application was assessed against the benchmarks applicable at the time and was refused due to:
Non-compliance with the maximum permitted gross floor area;
Ecological and water quality reports submitted with the original application being outdated;
An updated bushfire management plan not being provided;
The approval being contrary to the Planning Regulation assessment benchmarks for development in a koala habitat area;
The community being unlikely to be aware of the approval given significant time had lapsed since the public notification of the original application; and
A further development application being likely to generate submissions raising valid grounds of objection to the proposed development’s non-compliance with The Noosa Plan given the site’s significant location and environmental values.
On 20 August 2018 Council was notified that the applicant had lodged an appeal to the Planning and Environment Court seeking the Court extend the currency period. At the 20 September 2018 Ordinary Meeting it was resolved to defend the appeal.
Notably, the current court proceedings have been paused until the assessment of this application is finalised, which is required by 20 March 2020 by the Court. The original approval remains current until such time as the court decides the appeal.
site details
The site is generally triangular in shape, comprises 5453m2 and has frontage to Noosa Drive. The western boundary of the site is adjacent to Weyba Creek. The land located to the north of the subject site is developed with 149 multiple dwelling units and resort facilities.
The site has a north-westerly aspect, with a gradual slope towards the west, adjacent to Weyba Creek. The Department of Agriculture and Fisheries identifies Weyba Creek as a ‘Fish Habitat Management Area A’.
The site is identified as including “essential habitat” by the State Regional Ecosystem mapping as it contains species that are endangered, vulnerable, threatened or rare (the Nature Conservation Act 1992) which are known to utilise this habitat including koalas and acid frogs.
The site has a split zoning with generally the front portion zoned Semi-Attached Housing and the rear Open Space Conservation. The Semi-Attached Housing Zone applies to approximately 3817m2 of the site, which represents 70% of the total site area. The remaining 30% of site is zoned Open Space Conservation. This area is primarily situated directly adjacent to the Weyba Creek Bushland Reserve.
The following image details the split zoning applicable to the site.

Figure 6: Zoning Plan
Surrounding Land Uses
North: RACV Resort which is accessed via an easement through the subject site and Weyba Creek Bushland Reserve.
South: Road reserve and Noosa Drive
East: Road reserve and Noosa Drive with developed Detached Housing Zone land beyond.
West: Weyba Creek Bushland Reserve

assessment
Instruments for Statutory Assessment
Under the Planning Act 2016 the application must be assessed against each of the following statutory planning instruments to the extent they are relevant to the development:
State Planning Policy;
South East Queensland Regional Plan;
Planning Regulation 2017;
The Noosa Plan.
Statutory Process
The applicant has requested to make a minor change to a development approval under s78 of the Planning Act 2016. An application for a minor change to a development approval can only be made in circumstances where a change would constitute a ‘minor change’ as defined by the Planning Act 2016.
The proposed plans include 3 visitor car parking spaces which are provided on the adjoining land. The original application form (2006) noted that the application was over Lot 3 on SP126203 (subject site) and Easement B on SP126206 on the adjoining land for access purposes. The current plans do not clearly demonstrate that the car parking is included within the Easement. It appears that the car parking is partly outside of the easement and therefore the application should also be made over Lot 203 SP267424.
A change application which applies to a new parcel of land does not constitute a minor change and a new application would be required.
Land dedication
The existing approval recognises the environmental qualities of the land in the north-eastern corner of the site and requires the area to be dedicated to the Crown (with Council as Trustee) for environmental protection purposes. The current application proposes that an environmental covenant be applied to this area as opposed to the land being dedicated. Adjoining land to the north of this area was previously dedicated to the Crown as part of the development of the RACV resort. Dedication of the land to the Crown is the preferred outcome as it will result in a contiguous and consistent Crown land tenure arrangement and provide for the long term protection of koala habitat and maintain a known koala linkage.
The following image details the area of land currently required to be dedicated:

Figure 7: Area of land to be dedicated (outlined in red)
Bushfire Management
The current State Planning Provisions relating to bushfire came into effect after the original approval. The current bushfire hazard mapping assesses bushfire hazard differently to the previous bushfire mapping used in the original assessment. When assessing the original application, the hazard assessment concluded the site had a low hazard status and that there was no need for any bushfire measures to make the site safe. The current State Planning Policy Bushfire mapping identifies that part of the footprint of the proposed development is of high potential bushfire intensity and is within a potential impact buffer.
A Bushfire Management Plan (BMP) was submitted with the current application and identifies two bushfire management zones for bushfire hazard protection. The zones are referred to as ‘Understorey Management Zone’ and ‘Landscape Management Zone’.
The following image is a site plan detailing the proposed management zones. The Understorey Management Zones (UMZ) is identified by the area with red hatching whilst the Landscape Management Zone (LMZ) is hatched blue:

Figure 8: Site Plan – Bushfire
The UMZ is wholly contained within the area of the site zoned Open Space Conservation, and required to be dedicated for environmental purposes. It is proposed that trees up to 5 metres in height will be removed within this area, with groundcover, regularly maintained with plants to not exceed 400mm in height. All trees including the Eucalyptus robusta greater than 5 metres in height within this zone are to be retained.
The LMZ requires landscaping to be regularly managed by gardeners, requiring the removal of weeds and dead vegetation material. The applicant notes that some koala habitat trees may be retained and planted in this area and landscape species is to include local, less flammable, plant species.
The BMP also requires that planting of koala habitat trees occurs at a density no greater than 1 tree per 8m2 and that no tree be planted within 8 metres of any structure. The BMP suggests that based on the size of the UMZ, approximately 478m2, that an additional 60 koala habitat trees could be planted in the UMZ. This suggestion does not appear to acknowledge approximately 28 existing trees already located in this area which are proposed to be retained. In this regard, only 32 trees additional could be planted in this area, however their growth would be influenced by competition from the existing trees. The successful maturation of the planted koala food trees in this area is therefore questionable.
Whilst the proposed bushfire management plans may provide a functional solution from the threat of bushfire, the proposed mitigation actions rely on the clearing of vegetation within the part of the site required to be dedicated to the Crown and zoned Open Space Conservation and is not supported. The removal of trees less than 5 metres in height and the modification of the understorey will also have a detrimental effect on the environmental values of this part of the site and impact on the ability of this area to provide a buffer to the adjoining wetland.
Furthermore, the suggestion within the BMP that koala habitat trees be replanted within the UMZ raises concern as it is contrary to the requirement that trees less than 5 metres in height be removed from this area. It is unclear as to how one component of the BMP can require trees less than 5 metres in height be removed but also support the re-planting of the same vegetation.
Accordingly, the proposed bushfire management plan is not supported as it proposes vegetation removal and management within a part of the site which is zoned Open Space Conservation and includes elements which are contrary with each other.
Koala habitat
The site is currently mapped as being located within a Koala Assessable Development Area (KADA) under the superseded State Planning Regulations Provisions mapping. It is also mapped as “generally not suitable” habitat for koalas. Due to the site’s location in a KADA the application requires assessment under the assessment benchmarks listed in Schedule 11 of the Planning Regulation 2017. These include that the site is designed to provide safe koala movement opportunities and consider habitat connectivity values of the site. Native vegetation clearing is also required to be undertaken in a sequential manner and under the guidance of a koala spotter where the native vegetation is a non-juvenile koala habitat tree and landscaping activities provide food, shelter and movement opportunities for koalas consistent with the site design.
The Noosa Plan requires that development avoid impacts on koala habitat areas and provide ecological linkages for safe and appropriate koala movement.
Council’s consulting ecologist advises that the re-planting of koala habitat trees on site to provide 'no net loss' would produce an adequate outcome for koalas at this particular site in terms of habitat. However, the proposed measures to achieve no net loss of koala habitat are not practical due to bushfire requirements as the vast majority of the identified re-planting zones, aside from the UMZ, are incapable of being re-planted due to their proximity to structures. A 126m2 area within the north-eastern corner of the site already contains significant canopy coverage these areas however are within proximity of power-lines and are likely required to remain cleared to provide clearance to the power lines and to allow for satisfactory sightlines for vehicles exiting the site. The area proposed for replanting within the UMZ is also already vegetated and the density of vegetation in this area will mean replanted vegetation will compete with existing vegetation and hinder their development into adequate koala food trees.
Furthermore, a number of existing trees proposed to be retained are located within close proximity of the proposed buildings and internal access driveway. Retention of large Koala food trees amongst buildings and within vehicle and pedestrian frequented areas, is likely to be compromised by construction activities and future demands for risk mitigation, and inevitably result in the trees being lost from the landscape.  The applicant has proposed the use of pervious paving to maintain surface water penetration for the koala food trees, however this measure is redundant considering the high water table. The koala food trees are largely reliant on ground water and the provision of permeable paving to allow surface water to penetrate to the ground is of inconsequential value. In addition the construction of the permeable paving will have a similar impact on root zones of koala food trees compared with the construction of a standard impermeable paving.
An acoustic report was provided in the original application and included a recommendation that a 2 metre high acoustic fence be constructed and in part setback 2.0 metres from the property boundary. This recommendation was included as a condition of the approval. The acoustic fence has not been adequately considered in the applicant’s determination of koala habitat loss. The construction of an acoustic fence to the Noosa Drive boundary is likely to result in further tree clearing and further compromises the ability to retain suitable koala habitat in-situ.
The loss of koala food trees from the site has the real potential to be deleterious to Noosa’s koalas. The trees proposed to be removed also currently provide a linkage for koala movement and consequently the proposal fails to maintain linkages for koala movement through the site. As such, the proposal does not satisfy the requirements of the Planning Regulation or the Noosa Plan as it does not sufficiently retain vegetation and provide for safe koala movement opportunities.
Change to planning framework – South East Queensland Koala Conservation Strategy 2019 - 2024
Under the new South East Queensland Koala Conservation Strategy 2019-2024 mapping, the site is mapped as Koala Habitat Area. As such, if an application was lodged today, the proponent would be required to comply with the State Code 25: Development in South East Queensland koala habitat areas and provide environmental offsets to the State in accordance the Environmental Offsets Act 2014.
The applicant has advised that the preferred outcome for koalas would be to provide “offset” tree planting elsewhere in the locality on a site to be negotiated with Council or if necessary, a financial offset arrangement could be made in accordance with the State environmental offsets legislation. In this instance, replanting off-site or a financial contribution to achieve an offset is not fully supported as it is important that the physical linkage for koala movement is maintained through the site.
The following image details the mapped Koala Habitat Area on the site and surrounding land.

Figure 8: Koala Habitat Area (green) effective 7 February 2020
Stormwater
The stormwater management requirements as part of the original approval for the site are not compliant with the current Sate Planning Policy for Stormwater.
The current application has sought to address this by providing a letter from a civil engineer which details an amended stormwater management regime and concludes that the proposed treatment train exceeds the requirements of the state planning policy.
Council’s consulting water engineer has reviewed the proposed stormwater management and has raised concerns regarding the suitability of the stormwater modelling as it does not address runoff from the internal access road and is required to.
The proposed pervious paving to the internal access road also relies on strict maintenance. Maintenance requirements have not been provided however would rely on removing debris from the porous system of the permeable paving. The removal of this debris by hosing or waterjet would also increase the nutrient inputs into the surrounding nutrient sensitive environment.
Gross Floor Area (GFA)
In 1999, prior to the approval of the original application, the landowner dedicated 236m2 of land to Council for the construction of the Noosa Drive roundabout. The dedication formed part of an Infrastructure Agreement (IA) between Council, the landowner and the landowner of the adjoining property. The IA also required that any future application for development approval take into account the area of 236m2 for the purposes of assessing site density.
Therefore at the time of the original approval a maximum GFA of 1896m2 was permitted, being reflective of the permissible GFA attributable to that part of the land zoned Residential Low Density and the 236m2 for the roundabout. This exceeds the current requirements of the Noosa Plan which permits a maximum GFA of 1527.4m2. The maximum permissible GFA has reduced as the Noosa Plan has decreased the area of the land zoned for development by increasing the area zoned for environmental protection. Furthermore, the area is further reduced as the IA does not clearly specify that the consideration of the 236m2 associated with the dedication applies to successors in title.
The applicant has included a notation on the plans that the maximum GFA now proposed is to be approximately 1600m2. It is acknowledged that the proposed GFA exceeds the planning scheme requirements however it is considerably less than what is currently approved. Furthermore, it is important to note the draft Noosa Pan permits a plot ration of 0.65:1 which allows for a GFA of 2,482m2. As such there is no objection to the proposed GFA.
Building Height
In accordance with the planning scheme the maximum permissible height is 8 metres. In the supporting material supplied with the application the applicant advises:
The proposed built form is 2 storeys and 8m in height but might marginally exceed 8m from natural ground level to provide for a flooding minimum floor level of 2.8m (AHD) with a 5 degree roof pitch.
Elevation plans have not been provided to demonstrate the extent of non-compliance proposed. Where a variation to the planning scheme is proposed plans demonstrating the extent of non-compliance should be provided for review. In this instance, it is not reasonable to support the potential increased height without clear information and confirmation of the built form and the maximum height proposed.
draft planning scheme
The draft planning scheme rezones the site from Semi-Attached Housing Zone and Open Space Conservation Zone to Tourist Accommodation Zone and Environmental Management and Conservation Zone.
The Tourist Accommodation Zone code includes an outcome which seeks to protect a number of sites for the purpose of a resort complex or short term accommodation to the general exclusion of permanent residents. The subject site has not been included in the list of sites.
Specific to the subject site, multiple dwellings are identified as a consistent use which would be subject to an impact assessable application process.
It is also noted that the draft planning scheme increases the permissible plot ratio on the site from 0.4:1 to 0.65:1.
cONSULTATION
Referral Agencies
The application did not require referral to a Referral Agency.
Other Referrals
The application was forwarded to the following internal Council specialists:
Coordinator Development Engineering
Environment Officer
Strategic Planning Officer
The application was also reviewed by Council’s consulting ecologist and storm water engineer, and their comments form part of this report.
conclusion & reasons for decision
The application is for a minor change relating to a Development Permit for Material Change of Use - Multiple Dwelling (10 units) at 142 Noosa Drive Noosa Heads. In October 2018 an application to extend the currency period of the approval was refused by Council, with the decision subsequently appealed by the applicant. The original approval remains current until such time as the court decides on the appeal. The appeal is on hold to allow for a decision to be made on this minor change application.
The original application was made over the subject site and the easement on the adjoining land. As the proposed works extend beyond the easement on the adjoining land the application involves a new parcel of land and cannot be considered a minor change. The proposed change therefore requires a new application to be lodged for assessment.
The application modifies the footprint of the development and includes supporting documentation, seeking to address the grounds of refusal for the extension of currency period application. This material includes updated ecological reports, bushfire management plan and stormwater management plan.
The submitted bushfire management plan proposes removal and management of vegetation within the part of the site which is required to be dedicated to the Crown (with Council as trustee) for environmental purposes. Bushfire management works within this area are not supported.
In order to address the loss of koala habitat the applicant has proposed a re-planting regime to achieve no net loss. Whilst a no net loss approach is desirable the requirements of the bushfire management plan and impacts of construction, including an acoustic fence, will prevent retention of a significant number of trees and achievement of  adequate planting to result in no net loss to koala habitat and maintain a linkage for koalas through the site.
Furthermore, review of the submitted stormwater management plan shows that the modelling does not address all areas requiring stormwater treatment.
The application also proposes to amend the dedication of land to the creation of a covenant. This approach is not supported due to the adjoining land already being subject to Crown tenure and the preference that a contiguous land tenure arrangement prevail.
Consequently it is recommended that the application be refused.
Departments/Sections Consulted:
	Chief Executive Officer		Community Services		Corporate Services
	Executive Officer		Community Development		Financial Services
	Executive Support		Community Facilities		ICT
			Libraries & Galleries		Procurement & Fleet
			Local Laws		Property
			Waste & Environmental Health		Revenue Services
					
	Executive Services	x	Environment & Sustainable Development		Infrastructure Services
	Community Engagement		Building & Plumbing Services		Asset Management
	Customer Service	x	Development Assessment		Buildings and Facilities
	Governance		Economic Development		Civil Operations
	People and Culture	x	Environmental Services		Disaster Management
			Strategic Land Use Planning		Infrastructure Planning, Design and Delivery
					

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PLANNING & ENVIRONMENT COMMITTEE MEETING REPORT	10 MARCH 2020

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NOOSA SANCTUARY

SK. PARK
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» DEVELOPMENT PARAMETERS
4 4 ‘ Max Population 33 persons
a . Max Gross Floor Area 1896 sqm
NT PROPOSAL NF
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Min Landscape Open Space 1320 sqm
Max Building Height 2 storeys/8m


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