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Town Planning Report - 226 David Low Way
Attached to the e-mail Development Application MCU - 226 David Low Way Peregian Beach-Report & Form 24(Email 1).
Town Planning Report
Development Application
‘Peregian Beach Villas’
Adamson Town Planning Pty Ltd ATF
(ACN: 163 798 374 : ABN: 72 472 058 207)
P | (07) 5430 6671 F | 5430 6677 M | 0437 754 420 | PO Box 78, Peregian Beach, QLD, 4573
E | [email protected] | Web | www.adamsontownplanning.com.au
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TABLE OF CONTENTS
INTRODUCTION ..............................................................................................................................................3
SITE ...................................................................................................................................................................3
BACKGROUND ..................................................................................................................................................4
DEVELOPMENT PROPOSAL ............................................................................................................................5
PLANNING PROVISIONS ...............................................................................................................................5
SOUTH EAST QUEENSLAND REGIONAL PLAN ................................................................................................... 5
THE NOOSA PLAN 2006 ................................................................................................................................. 6
Eastern Beaches Locality Code .............................................................................................................. 7
Specific Outcomes ................................................................................................................................... 9
Amenity (O1) ............................................................................................................................................ 9
Character and function of the David Low Way (O2) ................................................................................ 9
Built Form (O3 & O4) ............................................................................................................................... 9
Setbacks (O5) ........................................................................................................................................ 10
Site Cover, Gross Floor Area and Plot Ratio (O6) ................................................................................ 10
Roof Form (O12).................................................................................................................................... 11
Sloping Sites (O13)................................................................................................................................ 11
Semi-Attached Housing Zone ................................................................................................................ 11
Consistent and Inconsistent Uses (O29 & O30) .................................................................................... 11
Streetscape and Character (O32) ......................................................................................................... 11
Garages and Carports (O33) ................................................................................................................. 12
Overlay Codes ....................................................................................................................................... 12
DRAFT SUNSHINE COAST PLANNING SCHEME ............................................................................................... 12
STATE PLANNING POLICY ...........................................................................................................................14
KOALA CONSERVATION ................................................................................................................................ 15
STATE REFERRALS ........................................................................................................................................15
CONCLUSION .................................................................................................................................................16
ATTACHMENT 1 – PROPOSAL PLANS ............................................................................................................. 17
ATTACHMENT 2 – LANDSCAPING PLAN .......................................................................................................... 18
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Introduction 1. The purpose of this report is to provide town planning advice for a development application for a development permit for nine (9) dwelling units at 226 David Low Way, Peregian Beach. 2. The development application is for a material change of use for Multiple Housing – Type 4 Conventional and Visitor Accommodation Type 4 – Conventional. It is intended that the proposed dwelling units be used for both permanent residential and visitor accommodation purposes. Site 3. The subject land is described as Lot 12 on SP 207105, has an area of about 1,200m² and is located on eastern side of David Low Way (refer Figure 1). Figure 1 – Locality Plan 4. The parcel of land is unique because it is one of the last remaining vacant parcels near the Peregian Beach neighbourhood centre. The land is relatively flat and has a gentle slope from the northwest to the southeast. 5. The subject site is located to the north of the ‘Peregian Boardwalk’ development, which is a mixed use development that fronts David Low Way, Heron Street and Kingfisher Drive. To the east is a dwelling and a vacant parcel of land that fronts Kingfisher Drive. To the north east is a modern duplex development and further to the north east is a multiple dwelling unit development, which also fronts Kingfisher Drive. Adjoining the site to the north is another duplex development and further to the north again is a small multiple dwelling development. ‘Peregian Beach Villas’ Development Application – January 2014 Page 3
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6. On the opposite side of David Low Way is the Peregian Hotel, residential houses
directly opposite the site, a commercial office development further to the north
along with the Peregian Beach Bowls Club site.
7. The character of the area is mixed, with commercial development mostly beside
the Peregian Beach Neighbourhood Centre and residential development including
houses and multiple dwellings in the immediate locality.
8. A small substation and easement is provided in the south west corner of the land,
which was required for the ‘Peregian Boardwalk’ development (refer Figure 2).
An easement also exists within the property along the north eastern boundary
and contains a sewerage main.
9. Access to the proposed development is from David Low Way, being is left in and
left out, which is desirable at this location. The site is generally devoid of any
significant vegetation (refer Figure 2).
Figure 2 – Aerial Photograph
Background
10. Previously the subject land contained a motel development, which was
demolished some time ago. A new development approval was obtained over the
land for material change of use (Visitor Accommodation Type 4 – Motel), which
was to lapse on 5 October 2013. However, an application to extend the relevant
period of this approval was lodged on 18 September 2013, but has not been
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decided. Consequently, the approval remains current and has not lapsed and is
relevant to the assessment of the proposal.
11. The motel approval provides for 12 visitor accommodation units and a managers
dwelling unit contained in a two (2) storey building. The proposed motel also
provides in house dining and other ancillary facilities for guests.
12. The owner has advised that the land has been for sale for some time, but despite
having the abovementioned approval, it has not sold. At the present time there
would appear to be little interest in developing the land for this purpose.
13. Under the conditions of the motel approval, a number of development
parameters are stipulated to ensure that the built form is in keeping with the
existing streetscape and the character of the area. These development
parameters are discussed further below. The proposed development is generally
consistent with scale of that approval.
Development Proposal
14. It is proposed to provide nine (9) multiple dwelling units on the land in four (4)
separate buildings. A copy of the proposal plans is provided as Attachment 1. A
landscaping plan is also provided as Attachment 2. Further, plans are also to be
provided that show the treatment of and disposal of stormwater drainage from
the site.
15. The proposed development is comprised of four (4), two (2) storey buildings that
utilise light weight building materials. The design is modern and makes use of
varying roof lines and pitches, roof overhangs and open balconies. The building
materials include aluminium windows and screening, cladded walls and timber
posts and metal roof sheeting.
16. It is intended to provide 8 x 1 bedroom units and 1 x 2 bedroom unit on the land.
Based on local research, there is currently a demand for 1 bedroom dwelling
units in the locality. Expressions of interest have been invited, with a number of
enquires being received.
17. While a study area is provided within each of the units, no door is provided to
this room and access to the ablution facilities is also required through this room.
Consequently, this room cannot be considered a bedroom. Further, a multi-
purpose room is also provided at the ground level of Unit 5, this room also
provides access from the garage and to the private open space area.
Consequently, this room is also not intended to be used as a bedroom.
18. It is proposed to provide a covered carparking space for each of the units as well
as three (3) visitor carparking spaces within the development (refer Site Plan –
Attachment 1). Significant landscaping is proposed to the frontage of the site
and within the building setback areas (refer Attachment 2).
Planning Provisions
South East Queensland Regional Plan
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19. The land is included in the Urban Footprint and does not offend any of the
provisions of the Regional Plan. The proposed development is considered to be
consistent with the intent of the Regional Plan by providing higher density
residential development in close proximity to a neighbourhood centre and near to
public transport.
The Noosa Plan 2006
20. Under the Noosa Plan the site is included in the Eastern Beaches Locality and is
included in the Semi-Attached Housing zone (refer Figure 3). Under the planning
scheme the uses applied for are defined as:
Multiple housing means the use of premises for two or more dwelling units
or accommodation units as the case may be, occupied by permanent or semi-
permanent residents, where the occupants may share common facilities on
the site.
21. The term includes Type 4 – Conventional:
Means the use of premises for dwelling units that do not fall within Multiple
housing Types 1, 2, 3, or 5. The use includes units, townhouses, flats,
apartments, villas and small dwelling units.
Visitor accommodation means accommodation that is designed and
predominantly used for visitors to the Shire and where social, recreational
and dining services may be provided for visitors by owners or staff.
22. The term includes the following types:
Two or more dwelling units or accommodation units, for the purpose of
providing short-term visitor accommodation. The use may include common
recreation or dining facilities and includes an ancillary dwelling unit for onsite
manager. The use includes a guesthouse, visitor hostel, motel, resort and
serviced rooms, but does not include Visitor accommodation Type 1
Home hosted or Type 3 Rural as separately defined.
23. According to the development assessment table1, both Multiple Housing Type 4 –
Conventional and Visitor Accommodation Type 4 – Conventional are impact
assessable uses in this zone.
24. The most relevant codes for the assessment include:
• Eastern Beaches Locality Code;
• Residential Uses Code;
• Landscaping Code; and
• Engineering Works Code.
1 Noosa Plan 2006, Table 7.2, page 7-8
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Subject Site
Figure 3 – Noosa Plan 2006
Eastern Beaches Locality Code
25. The most relevant overall outcomes2 sought for the Eastern Beaches Locality
include the following:
a) New uses and works are located, designed and managed to-
i. be compatible with other uses and works;
ii. maintain the safety of people and works;
iii. avoid significant adverse impacts on the amenity enjoyed by
users of other premises, including acoustic and visual qualities;
iv. avoid significant adverse impacts on the natural environment,
including native habitat removal, fragmentation and attrition;
and
v. protect the natural beach experience and overall visual amenity
for beach users;
b) The Eastern Beaches Locality retains its primary role as a residential
area, though continues to provide some visitor accommodation and a
range of local retail and commercial functions at Sunshine Beach,
Sunrise Beach and Peregian Beach;
c) The scale and form of buildings and other structures are –
i. designed to be responsive to the informal beachside character of
the locality, being low rise buildings, with pitched or curved roofs
and building materials that blend with the dune and coastal
landscape;
ii. in keeping with the surrounding streetscape and landscape
qualities;
2 Noosa Plan 2006, Part 7.8, page 7-26
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iii. integrated into the topography and native vegetation of the
dune system which dominates the locality; and
iv. consistent with the amenity and safety expectations of the
community;
d) …
p) For Peregian Beach –
i. Peregian Beach provides a mix of detached houses,
Multiple housing and Visitor Accommodation for
residents and visitors;
ii. Multiple housing Type 2 Duplex and Visitor
Accommodation Type 4 Conventional are located in close
proximity to the Peregian Beach neighbourhood centre shown
in the Neighbourhood Centre Zone;
iii. a wide range of local Retail, Commercial and Entertainment
and Dining Uses within the neighbourhood centre serve the
immediate needs of residents and visitors of the locality;
iv. the neighbourhood centre provides an informal village-like
atmosphere, with a low key, attractive and safe village square
that engenders a ‘sense of place’ and a public focus for local
community interaction and activity; and
v. …;
q) …
r) For the Semi-Attached Housing Zone—residents are accommodated in
Detached housing forms or Duplexes that –
i. provide a low impact, low density development which respects
the domestic scale of surrounding detached housing;
ii. offer a high level of residential amenity, design quality and
safety; and
iii. express a coastal building style that integrates with the
landscape and topography;
s) …
26. The proposed development complies with these overall outcomes for the
following reasons:
a) the proposed use is compatible with other uses in the immediate
locality and will not adversely impact upon the amenity of the area
from either a visual or acoustic quality perspective;
b) the proposed development is for a residential purpose and therefore
contribute to retaining its role as a residential area and will provide for
both multiple housing and visitor accommodation;
c) the scale of the built form is of domestic appearance within a
landscaped setting, is low rise and designed to be integrated with the
natural land form. The built form also provides for a high level of
residential amenity, design quality and safety;
d) the design incorporates pitched roofing and building materials that are
in keeping with the coastal building style and the surrounding
streetscape and landscape qualities;
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e) the proposed development will be compatible with existing village-like
atmosphere, is considered to be low key and an attractive
development that adds to the ‘sense of place’;
f) the proposed development is low impact, relatively low density, with
respects the scale of surrounding residential development; and
g) the proposed development is also consistent with the reasonable
expectations of the general community.
Specific Outcomes
27. A number of the specific outcomes of the Eastern Beaches Locality Code are also
relevant to the assessment and are discussed below.
Amenity (O1)
28. The proposed development has been designed and will be operated to avoid
significant adverse impacts upon the amenity of adjoining and nearby properties.
This includes consideration of the design to protect the amenity of neighbouring
properties.
29. An 1800mm fence to be provided on the property boundaries to maintain the
amenity of neighbouring properties and any lighting within the property is to be
hooded to prevent spillage.
Character and function of the David Low Way (O2)
30. Significant landscaping is proposed to the David Low Way frontage to maintain
the vegetated character of the roadway. The vegetation to be provided will
contain trees of a size that will contribute positively to the streetscape when
viewed from the street (refer Attachment 2).
31. The proposed development will not adversely impact upon the function, capacity
and efficiency of the David Low Way. An appropriate amount of carparking is also
to be provided on site.
Built Form (O3 & O4)
32. The proposed development will have low site impact given the relatively level
grade and has been designed to integrate with the natural land form. The
proposed buildings will be two (2) storey, but less than 8m in height and will be
compatible with the surrounding development.
33. The subject site has an area of about 1,200m². The density provided under the
planning scheme is 100 persons per hectare, which equates to 12 persons. The
proposed development has a theoretical population density of 16.0 for the 9
dwelling units and a theoretical population density of 13.6 persons for 9
accommodation units.
34. Importantly, the existing motel approval over the land has a theoretical
population density of 18.2 persons. While the proposed development exceeds the
allowable density under the planning scheme, it is less than the current approval
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over the land. This is considered reasonable given the nature of the development
being primarily one (1) bedroom units, for which there appears to be a demand.
35. The proposed development is two (2) storeys and less than 8m in height. The
development is infill development, does not dominate the street or the adjacent
properties and protects the amenity of the area.
Setbacks (O5)
36. It is intended to construct the nine (9) units within four (4) separate buildings,
rather than a single large building. The frontage of the site is of an irregular
shape and is also constrained by a substation easement on the southern side.
The rear north eastern allotment boundary is also irregular and constrained by an
easement, which is about 2.5m in width and parallel to this boundary.
Consequently, it is difficult to provide a design with separate buildings and meet
all setback requirements.
37. The proposed development has building setbacks that vary at the frontage due to
the above constraints. The setbacks to the David Low Way vary and are about
6m towards the northern part of the frontage and about 4.5m towards the
southern end. In the middle of the frontage there is a very small portion of a
building that is about 4m from the boundary, near the driveway.
38. While the front building setbacks are within 6m, the design maintains the visual
continuity and pattern of buildings in the street. Further, the average frontage
setback is generally consistent with the setback of the ‘Peregain Boardwalk’
development, which is also about 4.0m. Significant landscaping is also proposed
to the frontage of the development, which will reduce the impact of the built form
and provide an acceptable streetscape.
39. The side boundary setbacks comply with Schedule 1 and the building code. The
rear setback is 5.875mat the closet point, which is considered acceptable.
40. The proposed building setbacks maintain the amenity of users of adjoining
premises by preserving the visual and acoustic privacy. The design allows for
significant landscaping to be provided to the frontages. Consequently, the visual
continuity and pattern of development is also generally consistent with existing
development in the immediate locality.
Site Cover, Gross Floor Area and Plot Ratio (O6)
41. The proposed development has a GFA of about 541m². The allowable GFA under
the planning scheme equates to 480m². However, the current motel approval
allows for a GFA of 528m². The GFA is larger because of the separate built form
and also allows for some visitor parking to be provided behind the building.
42. While the GFA of the development is more than that allowed under the planning
scheme and the current motel approval, this is considered acceptable given the
nature of the design with four (4) separate buildings rather than a single large
building, which is considered to be a more desirable planning outcome.
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43. The proposed development has a site cover of 479.5m², which equates to 40%
and complies with the planning scheme.
44. It is suggested that the proposed development is of a scale that is compatible
with surrounding development and does not present an appearance of excessive
bulk when viewed from the street or neighbouring properties. The built form is
also softened by significant landscaping to the frontage. Sufficient area at ground
level is provided for outdoor recreation and other facilities.
Roof Form (O12)
45. The proposed roof form is articulated and varies in slope direction, height and
appearance. The pitch of the roofing varies between 7 degrees and 14 degrees
and also in direction. The roof is to be constructed of metal sheeting with roof
overhangs.
46. The roof is pitched and will contribute positively to the skyline with the building
treatments making for an interesting design. The proposed development is in
keeping with the character of development in the locality.
Sloping Sites (O13)
47. Minimal cut and fill is required in order to provide a level building platform, which
is needed for this type of development and is appropriate for the site.
Semi-Attached Housing Zone
Consistent and Inconsistent Uses (O29 & O30)
48. Within the Semi-Attached Housing Zone, Multiple Housing Type 4 – Conventional
is a consistent use, because the land area is more than 800m². While Visitor
Accommodation Type 4 – Conventional is not a consistent use, it is the same use
that has been approved on the land previously and an approval for the use
remains current. From a town planning perspective it is desirable to provide for
visitor accommodation in this coastal location and in close proximity to the
neighbourhood centre of Peregian Beach.
49. While there is some conflict with the planning scheme with respect to the visitor
accommodation use not being consistent in the zone, there are grounds that are
sufficient to overcome the conflict.
Streetscape and Character (O32)
50. The proposed built form contributes positively to the streetscape character by
addressing the street and adding visual interest. The bulk and architectural scale
does not dominate the streetscape or detract from the visual amenity of adjoining
properties.
51. The proposed development comprising four (4) separate buildings presents as
having a domestic scale and appearance within a landscaped setting. The design
also has good articulation with the garages not dominating the street.
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Garages and Carports (O33)
52. The design of the proposed development provides for single garages for each
dwelling unit and three (3) visitor carparks. The design is such that none of the
garages front the street, with the exception of the garage for Unit 5, which is
setback from the frontage.
53. Two (2) of the visitor parking bays are near the frontage, but will be screened by
landscaping. The third bay is hidden from view between Units 3 and 4. The
proposed parking is integrated with the built form and does not dominate the
street.
54. A single vehicle access point is also provided with safe and efficient access to and
egress from the premises, being left in and left out in a forward direction, which
is desirable given the site fronts a major collector road.
Overlay Codes
55. According to the mapping for the Eastern Beaches Locality, the subject land is
not affected by any overlay mapping. Consequently, no assessment is required
against any of the overlay codes.
Subject Land
Figure 4 – Zone Map ZM 23
Draft Sunshine Coast Planning Scheme
56. The draft planning scheme for the Sunshine Coast region has been advertised
and submissions received. It is understood that the Sunshine Coast Council has
not considered any submissions for the Noosa area, including a submission made
to include the subject land in the Local Centre Zone. However, since this occurred
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the new Noosa Council has been formed and the planning intentions for the
locality are likely to be reviewed and this is likely to take some time.
57. While the draft planning scheme provisions could not be given much weight in
the circumstances, it is appropriate to consider the key intentions. All of the land
has been included in the Medium Density Residential Zone (refer Figure 4
above).
58. Under the Noosa Eastern Beaches Local Plan Code a number of overall outcomes
are provided. The most relevant overall outcomes are discussed below:
f) The form and scale of all development is generally low key with buildings that
are low rise and cover a comparatively small area of a site thereby leaving
significant areas for landscaping and private open space. Development
complies with the maximum height in storeys and maximum site cover
requirements specified in this code.
m) Development in the Medium density residential and High density residential
zones provides for lot sizes, densities and building design which is consistent
with the character of the particular community.
n) Development retains identified sites for low cost visitor accommodation in
order to maintain a diversity of housing and visitor accommodation price
points in the local plan area.
59. The proposed development is low key with buildings that are low rise and areas
provided for landscaping and open space. The development is located in the
medium density area and is of a size, density and building design, which is
consistent with the character of the locality. The proposed development is also for
low cost visitor accommodation that provides for a diversity of housing types in
the locality. Consequently, the proposed development does not offend the overall
outcomes.
60. The purpose of the Medium Density Residential Zone Code is to be achieved by
meeting the overall outcomes. The most relevant outcomes include:
a) development provides for a mix of low and medium density residential
activities, predominantly for permanent living, including dwelling houses, dual
occupancies, multiple dwellings (such as townhouses, terrace and row
houses), residential care facilities and retirement facilities;
b) other multi-unit residential activities such as hostels, relocatable home parks
and short-term accommodation may also be established where their scale and
operation is compatible with, and does not detract from, the existing and
intended residential character and amenity of the zone;
c) …
e) development caters for a low rise built form;
f) …
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i) development that is multi-storey ensures that there is no unreasonable loss of
amenity for surrounding development having regard to:-
i. microclimate impacts, including the extent and duration of any
overshadowing;
ii. privacy and overlooking impacts;
iii. impacts upon views and vistas; and
iv. building massing and scale relative to its surroundings;
j) development is designed and located in a manner which makes a positive
contribution to the streetscape and is sympathetic to the existing and
intended scale and character of surrounding development;
k) development incorporates a high level of residential amenity, safety and
design quality and is set within attractive landscaped grounds;
l) …
m) development is located, designed and operated to be responsive to the
Sunshine Coast’s sub-tropical climate and minimises the consumption of
energy and water;
n) except where varied by a local plan code in Part 7 (Local plans), development
provides for:-
i. the uses listed as consistent uses in column 1 of Table 6.2.2.2.1
(Consistent uses and inconsistent uses in the Medium density
residential zone) to occur in the Medium density residential zone;
and
ii. the uses listed as inconsistent uses in column 2 of Table 6.2.2.2.1 not
to occur in the Medium density residential zone.
61. The proposed development is located in the Medium Density Zone, and according
to Table 6.2.2.2.1, the uses applied for are consistent within the zone (the uses
being Multiple dwelling and Short-term accommodation).
62. The proposed development is of a scale that compatible with and will not detract
from the existing and intended character and amenity of the locality. The
proposed development also makes a positive contribution to the streetscape and
provides for a high level of residential amenity with attractive landscaped
grounds. In my opinion, the proposed development satisfies the overall outcomes
of the code.
State Planning Policy
63. On 2 December 2013, the integrated State Planning Policy (SPP) took effect
replacing all other State planning policies. Consequently, it is necessary to
consider the SPP to the extent that it is relevant to the subject land.
64. According to the mapping provided by the Department of State Development,
Infrastructure and Planning, the subject land is affected by the following:
• Water Quality;
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• Natural Hazards – Flood Hazard Area (Local Government flood mapping
area);
• Strategic Airports and Aviation Facilities – Operational Airspace.
65. With respect to the matter of water quality, this issue is to be addressed with the
submission of a Stormwater Drainage Management Plan under separate cover. In
any event the subject land is less than 2,500m² and therefore the SPP does not
apply.
66. According to the overlay mapping under the planning scheme, the subject land is
not affected by flooding in a Q100 storm event. Consequently, the SPP does not
apply.
67. The subject land is located in potential operational airspace, however the
development is below 12m in height and therefore the SPP does not apply.
Koala Conservation
68. Under the SARA mapping, the subject land is located in a Koala assessable
development area (for information purposes only). However, the site has been
developed previously and does not contain any significant vegetation or Koala
food trees.
State Referrals
69. The subject site is located in the Management Area for Unexploded Ordinance
(UXO), refer Figure 5. Accordingly, the application is to be referred to the SARA,
pursuant to Schedule 7, 11 of the SPAR. The application is also to be assessed
against Module 12 of the State Development Assessment Provisions (SDAP).
70. In accordance with Performance Outcome (PO2) the area for which an area
management advice has been given for UXO is to be managed so that it does not
place another part of the environment, or human health, at risk. It is expected as
part of the referral process that a condition will be imposed by the Department of
Environment and Heritage Protection (DEHP), requiring that the land be
remediated suitable for the proposed use.
Figure 5 – Potential UXO
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71. The land also contains an easement that contains electricity infrastructure.
Accordingly, pursuant to Schedule 7(a) of the SPAR, the application is to be
referred to Energex for comment as an advice agency.
Conclusion
72. The proposed development is for both Multiple Housing and Visitor
Accommodation. Providing for both uses on the land allows for maximum
flexibility, which is desirable given the location of the land in a coastal village and
close to the neighbourhood centre. Further, the site has been vacant for a
considerable period of time and the proposal represents a good planning
outcome.
73. While the use of the land for visitor accommodation is not a consistent use in the
Semi-Attached Housing zone, the land has an approval for this use currently.
Further, there is some support for the use under the overall outcomes, where in
close proximity to the neighbourhood centre, which is the case here. It is also
noted that short term visitor accommodation is a consistent use in the Medium
Density zone under the draft planning scheme.
74. The scale of the development is considered to be compatible with other
development in the locality and also generally consistent with the scale of
development for the current motel approval over the land.
75. The design of the development is of light weight appearance and comprised of a
number of separate buildings and is in keeping with the character of the area
generally. The proposed built form and landscaping will complement the existing
streetscape.
76. The proposed development is consistent with the overall outcomes for the
Eastern Beaches Locality and does not offend any of the Desired Environmental
Outcomes under the planning scheme. To the extent there is any conflict with the
planning scheme it must be minor. There is considerable community benefit in
allowing the development given that it will provide additional housing choice in a
desirable coastal location and should be supported.
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Attachment 1 – Proposal Plans ‘Peregian Beach Villas’ Development Application – January 2014 Page 17
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Attachment 2 – Landscaping Plan ‘Peregian Beach Villas’ Development Application – January 2014 Page 18