Doepel Marsh Architects Pty Ltd and City of Subiaco
[2007] WASAT 293
•7 NOVEMBER 2007
DOEPEL MARSH ARCHITECTS PTY LTD and CITY OF SUBIACO [2007] WASAT 293
| STATE ADMINISTRATIVE TRIBUNAL | Citation No: | [2007] WASAT 293 | |
| PLANNING AND DEVELOPMENT ACT 2005 (WA) | |||
| Case No: | DR:43/2007 | DETERMINED ON THE DOCUMENTS | |
| Coram: | MR L GRAHAM (SENIOR SESSIONAL MEMBER) | 6/11/07 | |
| 19 | Judgment Part: | 1 of 1 | |
| Result: | The application for review is dismissed | ||
| B | |||
| PDF Version |
| Parties: | DOEPEL MARSH ARCHITECTS PTY LTD CITY OF SUBIACO |
Catchwords: | Town planning Application for approval to commence development Orderly and proper planning Preservation of the amenity of the locality Precedent Pylon sign Advertising signs policy Compatibility with existing and surrounding development |
Legislation: | City of Subiaco Town Planning Scheme No 4, cl 7(c), cl 26, cl 27(4), cl 28(3), cl 34, cl 37(2), cl 38 Metropolitan Region Scheme Planning and Development Act 2005 (WA), s 249(1) State Administrative Tribunal Act 2004 (WA), s 31 |
Case References: | Aspen Pty Ltd v State Planning Commission (Unreported; Appeal No 13 of 1988, 21 October 1988 Cipriano v City of Perth (Unreported, Appeal No 20 of 1979) Clive Elliott Jennings & Co Pty Ltd v WAPC (2002) 122 LGERA 433 Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634 Rajneesh Foundation of Australia v Shire of Manjimup (No 2) (1985) 3 SR (WA) 65 |
Orders | The application for review is dismissed. |
JURISDICTION : STATE ADMINISTRATIVE TRIBUNAL STREAM : DEVELOPMENT & RESOURCES ACT : PLANNING AND DEVELOPMENT ACT 2005 (WA) CITATION : DOEPEL MARSH ARCHITECTS PTY LTD and CITY OF SUBIACO [2007] WASAT 293 MEMBER : MR L GRAHAM (SENIOR SESSIONAL MEMBER) HEARD : DETERMINED ON THE DOCUMENTS DELIVERED : 7 NOVEMBER 2007 FILE NO/S : DR 43 of 2007 BETWEEN : DOEPEL MARSH ARCHITECTS PTY LTD
- Applicant
AND
CITY OF SUBIACO
Respondent
Catchwords:
Town planning - Application for approval to commence development - Orderly and proper planning - Preservation of the amenity of the locality - Precedent - Pylon sign - Advertising signs policy - Compatibility with existing and surrounding development
Legislation:
City of Subiaco Town Planning Scheme No 4, cl 7(c), cl 26, cl 27(4), cl 28(3), cl 34, cl 37(2), cl 38
Metropolitan Region Scheme
Planning and Development Act 2005 (WA), s 249(1)
(Page 2)
State Administrative Tribunal Act 2004 (WA), s 31
Result:
The application for review is dismissed
Category: B
Representation:
Counsel:
Applicant : N/A
Respondent : N/A
Solicitors:
Applicant : N/A
Respondent : N/A
Case(s) referred to in decision(s):
Aspen Pty Ltd v State Planning Commission (Unreported; Appeal No 13 of 1988, 21 October 1988
Cipriano v City of Perth (Unreported, Appeal No 20 of 1979)
Clive Elliott Jennings & Co Pty Ltd v WAPC (2002) 122 LGERA 433
Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634
Rajneesh Foundation of Australia v Shire of Manjimup (No 2) (1985) 3 SR (WA) 65
(Page 3)
Summary of Tribunal's decision
1 The application for review was lodged against a decision of the City of Subiaco to refuse the construction of a so-called "pylon sign" for advertising purposes at 61 Forrest Street, Subiaco.
2 The Tribunal examined the respective arguments of the parties, the background to the matter, the relevant legislative and policy provisions and matters of orderly and proper planning, amenity and precedent.
3 The Tribunal determined that the proposed advertising sign at 4.5 metres high would not be consistent with the existing signage on commercial premises nearby and would be contrary to the intent of the Advertising Signs Policy.
4 Also, the proposal was incompatible with nearby residential uses, would not preserve the amenity of the locality and that an approval could give rise to similar type developments elsewhere in the City. That could lead to an undermining of the Advertising Signs Policy.
5 The application for review was dismissed.
Introduction
6 The application for review, dated 24 January 2007, was lodged by Mr Kimbal Doepel of Doepel Marsh Architects Pty Ltd (applicant) against a decision of the City of Subiaco (respondent) on 5 January 2007 to refuse an application for approval to commence development for the construction of an advertising sign at 61 Forrest Street, Subiaco.
7 The application for review was lodged under the provisions of s 249(1) of the Planning and Development Act 2005 (WA).
8 The reasons for refusal made under direct delegation were:
"a) The proposal is not considered appropriate in its setting or the predominant character of the locality and the building has not been used as a frame for the new signage as required by the City's Advertising Signs Policy.
b) The proposal is not considered to meet Clause 27(4)(b) of the Scheme where by Council is to have regard to any relevant planning policy (specifically the City's planning policy 7.1 – Advertising Signs).
(Page 4)
- c) The proposal is not considered to meet Clause 27(4)(f) of the Scheme as the signage is not in the interests of orderly and proper planning of the locality.
d) The proposal is not considered to meet Clause 27(4)(g) of the Scheme as the signage is not consistent with the design, scale and relationship to existing buildings and surroundings of any proposed building or structure in the area.
e) The proposal is not considered to meet Clause 27(4)(h) of the Scheme as the signage is not consistent with the design, scale and relationship to existing buildings and surroundings of any proposed building or structure in the area.
f) The proposal is not considered to meet Clause 28 of the Scheme as it is considered that the signage is not consistent with:
i) the orderly and proper planning of the locality;
ii) the preservation of the amenity of the locality;
iii) the planning objectives of the particular zone and relevant precinct planning policies;
and the signage is considered to have an undue adverse effect on the likely future development of the locality …"
9 The subject land can be described as Lot 18 (No 61) Forrest Street, Subiaco and is located on the southern corner of the Forrest Street and Railway Road "T" intersection. It has an area of 498 square metres.
10 There is a two-storey commercial premises next door to the west with a frontage to Railway Road and a single storey residential structure to the east which operates as a commercial premises. The property directly opposite on the northern corner of Forrest Street and Railway Road is a single storey structure that operates as a commercial premises.
11 The subject property is owned by the applicant and his wife and they operate their architectural practice on the ground floor of the two-storey
(Page 5)
- building. There is also a tenant on the ground floor and an apartment is located on the upper floor.
12 The building is set back some 14.5 metres from the front boundary which allows for open car parking and landscaping within the front setback.
Legislative framework
13 The subject land is zoned "Urban" under the Metropolitan Region Scheme (MRS) and "Town Centre" under the City of Subiaco Town PlanningScheme No 4 (Scheme or TPS 4). It falls within the Town Centre Precinct as identified under TPS 4.
14 Of relevance is the Town Centre Precinct Planning Policy (1999) (Town Centre Policy) and the City of Subiaco – Policy 7.1: Advertising Signs (Advertising Signs Policy).
Respondent's position
15 The position of the respondent is outlined in a Statement of Issues, Facts and Contentions dated 11 May 2007. The respondent contends:
(a) The proposal is contrary to cl 27(4)(b), cl 27(4)(g) and cl 27(4)(h) of TPS 4 as it does not meet the requirements of the Advertising Signs Policy, does not conserve the amenity of the locality and is not consistent with the design, scale and relationship to existing buildings and surroundings of any proposed building or structure in the area.
(b) The proposed sign does not provide a positive contribution to the amenity and built form of the locality.
(c) The proposal does not meet cl 28(3) of TPS 4 as it is considered that the signage is not consistent with the orderly and proper planning of the locality.
(d) The proposal does not meet the requirements of the Advertising Signs Policy as the scale and design of the sign is incompatible with existing surrounding development, and the building is not used as a frame for new signage.
(Page 6)
Applicant's position
16 The position of the applicant is outlined in a "Statement of Issues, Facts and Contentions" dated 31 July 2007. The applicant opposes all of the respondent's contentions in [15] above and also argues:
(a) The applicant should be permitted to identify themselves on a sign located at the front boundary of the property facing Forrest Street, in a similar location to other signs in the locality.
(b) The occupants of the building should not be forced to identify themselves on a sign fixed to the front wall of the existing building which is set back 14.5 metres from the front boundary, merely to satisfy an inflexible application of Council policy.
(c) The Advertising Signs Policy should be applied flexibly taking into account the merits of the proposal.
(d) The proposed sign does contribute to the amenity of the locality.
(e) The proposed sign is consistent with the orderly and proper planning of the locality.
Planning issues
17 The principal planning issues are:
(a) Is the proposed advertising sign consistent with orderly and proper planning?
(b) Would the amenity of the locality be preserved with the construction of the proposed advertising sign?
(c) Would the scale and design of the proposed sign be incompatible with existing surrounding development?
Assessment of proposal
Background
18 The background to this matter includes:
(Page 7)
- (a) On 5 May 2006 the City conditionally approved an application for alterations and additions to an existing mixed-use complex on the subject land. The approved plans identified a 1.0 metre by 4.5 metre sign fronting both Forrest Street and Railway Road and annotated "sign to separate application".
(b) The application for development approval for the advertising sign was lodged with the City on 17 October 2006.
(c) The application was refused on 5 January 2007.
(d) An application for review was lodged with the Tribunal on 24 January 2007, whereupon the Tribunal, under s 31(1) of the State Administrative Tribunal Act 2004 (WA), invited the respondent on 21 February 2007 to reconsider its decision.
(e) At the April 2007 Planning Committee Meeting, and acting under delegated authority from Council, the Committee resolved "that the matter lie on the table".
The proposed development
19 The proposed development is described in the witness statement dated 15 August 2007 of Mr Kimbal W Doepel. He explains:
(a) The proposed development is a clean, integrated structure that includes a sign, letterbox and street number. It is intended to be located at the front north-west corner of the subject land.
(b) The structure is designed in an "L" shape to allow exposure to both Forrest Street and Railway Road. It measures 1 metre by 1 metre and is proposed at a height of 4.5 metres.
(c) The proposed structure is part of an integrated design solution with the adjoining two-storey building to the west at 105 Railway Road. It will match a 4.5 metre high physical element (steel services duct) on the adjoining building.
(Page 8)
- (d) The proposed sign location does not obscure any vehicle sight lines and therefore there are no traffic issues.
Legislative and policy provisions
Town Planning Scheme No 4
20 The objectives and intentions of TPS 4 are covered in cl 7. They include:
"…
(c) to foster and control the use and development of land in an effective, efficient and environmentally sustainable manner according to precinct planning principles."
21 Under cl 27 (Determination of Application: General Provisions) the Scheme advises:
"(4) Without limiting the scope of the Council's discretion to determine an application under subclause (3), the Council is to have regard to:
(a) the provisions of the Scheme … ;
(b) any relevant planning policies;
…
(f) the orderly and proper planning of the locality;
(g) the conservation of the amenity of the locality; and
(h) the design, scale and relationship to existing buildings and surroundings of any proposed building or structure ..."
" …
(3) The Council cannot grant development approval for a non-complying application unless, if so required by the
- Council under clause 26, the application has been advertised and the Council is satisfied that:
- (a) if approval were to be granted, the development would be consistent with:
(i) the orderly and proper planning of the locality;
(ii) the preservation of the amenity of the locality; and
(iii) the planning objectives of the particular zone and relevant precinct planning policies; and
(b) non-compliance would not have any undue adverse effect on:
(i) the occupiers or users of the development;
(ii) the property in, or the inhabitants of, the locality; or
(iii) the likely future development of the locality."
"(2) For each precinct listed below, there is a precinct planning policy.
…
4 Town Centre
…"
"Unless otherwise consistent with a planning approval, the development of land is to be in accordance with the standards and requirements contained in the Scheme Text, the planning policies and the Residential Planning Codes."
(Page 10)
25 In the view of the Tribunal there is an emphasis in the Scheme on orderly and proper planning and the conservation of the amenity of the locality. Also, that the design and scale of a proposed building or structure (such as an advertising sign) should have a relationship to existing buildings and the surroundings.
26 It is also the case that development decisions are to have regard to precinct planning policies and the planning principles contained therein. In this particular case the subject land falls within the Town Centre precinct.
27 What is also clear is that the respondent has discretionary powers built into its decision-making process, as outlined in cl 27(4) and cl 38 in particular.
Town Centre Precinct Planning Policy
28 The "Precinct Planning Objectives" include:
"6. to protect adjacent residential areas from any potentially negative impacts of development."
29 The "Desired Future Character" clause states:
"6. all aspects of developments will be considered to ensure effects on neighbouring properties in terms of noise, vibration, reflectivity, overlooking, overshadowing and other amenity issues are minimal."
30 Clearly, the intent of the Town Centre Policy is to complement the Scheme in terms of the effects of development on amenity in particular.
Advertising Signs Policy
31 The "Objectives" of the policy under cl 4 are to:
"…
• improve the quality and appropriateness of advertising signs through the application of good design principles.
• consolidate advertising signs where appropriate.
• limit the proliferation of advertising signs.
(Page 11)
- • ensure that advertising signs do not present a hazard or obstruction to pedestrians or block motorists' views of traffic information signs or traffic lights."
32 Under cl 5 there are standards for so-called "exempt" signs that do not require development approval and cl 6 (Signs that require development approval) includes the following:
"…
The City will generally not approve the provision of any of the following signs to a commercial premise because they do not provide a positive contribution to the amenity and built form of the locality. In addition, the City will not approve the provision of any of the following signs to a property used for residential purposes under any circumstances.
…
6.6 Pylon sign
A pylon sign is a stand-alone advertising sign supported by one or more piers and not attached to a building …"
"7.1 Appropriateness to setting
The design and scale of advertising signs should be appropriate to their setting and to the predominant character of the locality.
The City will consider the following matters when assessing advertising signs that require development approval:
• The scale and design of signs should be appropriate to the building to which they relate. The building should be used as a frame for new signage.
• The scale and design of signs should be compatible with existing surrounding development and be appropriate to the general nature of land use in the area.
- • Signs should not block important views, obscure architectural detailing or be detrimental to the amenity of nearby properties …"
34 Again, under cl 7 the policy states:
"7.4 Design
The following design principles should be considered when designing advertising signs:
• Advertising signs are generally most effective when they are simple and clear.
• An attractive or interesting building can act as a sign in its own right and also makes a positive contribution to the streetscape and the local community.
..."
36 It is also the case that a so-called "pylon sign" is generally not approved because of its perceived negative effect on amenity and the surrounding built form. That is to say that although a "pylon sign" could be approved under the discretionary powers available to the respondent, it is unlikely.
The matter of orderly and proper planning
37 For the purposes of this review, the matter of orderly and proper planning needs to be assessed on the basis of whether the proposed development accords with the relevant provisions of TPS 4, the Town Centre Policy and the Advertising Signs Policy.
38 If the circumstances are such that the proposal does not meet the relevant provisions in part or whole, a decision is still required as to whether the particular circumstances of the case justify an approval.
The matter of amenity and public consultation
39 The term "amenity" is defined in TPS 4 as:
(Page 13)
- "Amenity: means all those factors, which combine to form the character of an area and include the present and likely future amenity."
40 In Cipriano v City of Perth(Unreported, Appeal No 20 of 1979) "amenity" is defined at page 5:
"The sum of the expectations of the residents concerning the quality of their residential environment as determined by the character of the area, its appearance and land uses."
41 Again, in Rajneesh Foundation of Australia v Shire of Manjimup (No 2) (1985) 3 SR (WA) 65, Mr Malcolm QC (as he was then) expanded on the definition of amenity:
"In my opinion the likelihood of a proposed activity causing a nuisance is one way of testing whether or not a given activity will have a detrimental effect on the amenity of the locality …"
42 According to the Council's "Non Residential Assessment and Direct Delegation Report" of 20 December 2006:
"The proposal was referred to adjoining landowners for a period of fourteen days. No submissions were received."
43 The Tribunal understands that the applicant is the owner of the adjoining property to the west (105 Railway Road) and it does appear that only a limited number of owners were advised of the proposed development.
44 Accordingly, it is not possible to conclude that the absence of submissions accurately reflects the views of nearby landowners, one way or the other. This is particularly so with respect to the owners of residences on the north and south sides of Forrest Street to the east who would pass the proposed development enroute to Railway Road.
The matter of precedent
45 In the witness statement dated 13 August 2007 of Mr Timothy Clairfayt, a senior planning officer with the City, he states:
"… it is considered that the signage is considered to have an undue adverse effect on the likely future development of the locality as it could create an unwanted precedent for similar pylon signs to be constructed in the locality."
(Page 14)
46 In his witness statement Mr Doepel argues that he was unable to find one existing sign in the locality that was an integrated letterbox, street number and sign and that:
"… the clean integrated design of the identification sign proposed for our property should be considered on its merits and will not lead to an adverse precedent."
47 As explained in Aspen Pty Ltd v State Planning Commission (Unreported; Appeal No 13 of 1988, 21 October 1988:
"The precedent argument is not usually treated by this Tribunal as a 'stand-alone' argument. It is a consideration, but if there is no other reason why a development should not occur, the fact that it may tend to result in other applications being made for similar kinds of developments, should not be a reason why the appeal should be dismissed …"
48 The approach adopted in Aspen v State Planning Commissioniscontinued in this review.
The issue relating to the definition of "pylon sign"
49 In its "Notice of the Council's Decision" the refusal was for a "pylon sign".
50 In the witness statement of Mr Doepel he argues:
"53. My sign is not a pylon sign. When I designed the identification sign for our property I intentionally designed a sign that did not look like a typical fast food pylon sign. My sign is not supported by one or more piers. My sign is not supported by a pylon."
51 However, somewhat inconsistently, the applicant advised in the application for review that:
"The sign, the subject of this review can at best be referred to under Clause 6.6 Pylon Signs, although the sign, the subject of the DA application, does not resemble the illustration as depicted on page 7 of 9 of the Policy handout.
The definition however could be allocated to the application as "a pylon sign is a stand-alone advertising sign supported by one or more piers and not attached to a building"."
(Page 15)
52 In the respondent's "Written Submission In Reply To Other Party's Evidence" dated 22 August 2007 it advises:
(i) The proposed sign does meet the definition of a pylon sign.
(ii) Even if it did not meet the definition, the proposed sign would not be covered by Part 5 (Exempt Signs) of the Advertising Signs Policy.
(iii) The proposed sign would fall under a "catch-all" clause in Part 6 (Signs That Require Development Approval) which states:
"The following advertising signs, as well as any other type of sign not set out in Part 5 require development approval."
Conclusions
54 The application for review was lodged against a decision of the respondent to refuse the construction of a so-called "pylon sign" for advertising purposes at 61 Forrest Street, Subiaco.
55 The Tribunal examined the respective arguments of the parties, the background to the matter and the proposed development itself. Also, the relevant legislative and policy provisions were examined as well as matters of orderly and proper planning, amenity and public consultation, precedent and the definition of the term "pylon sign".
56 The position taken by the respondent is that the proposed development does not meet the relevant requirements of TPS 4 and the Advertising Signs Policy, is not consistent with orderly and proper planning, would not positively contribute to amenity and that its scale and design is incompatible with existing surrounding development.
57 The position of the applicant is that the proposed development is consistent with orderly and proper planning, that it would contribute to the amenity of the locality and that the provisions of the Advertising Signs Policy should be applied flexibly. Also, that the applicant should be
(Page 16)
- permitted to place a sign at the front of the subject land rather than it being positioned on a building set back 14.5 metres from the front boundary just to satisfy an inflexible application of Council policy.
58 The first point that should be put to one side is that the Tribunal would not dispute that the proposed L-shaped integrated structure to comprise a sign, letterbox and street number has been well designed by the applicant (a qualified and experienced architect).
59 However, the issue is not so much the quality of the design but whether a structure with two 1 metre wide sides to a height of 4.5 metres is appropriate on the subject land having regard to the circumstances of this case.
60 In examining TPS 4 it is clear that there is a strong emphasis on orderly and proper planning, the conservation of amenity and that the design and scale of a proposed building or structure (such as an advertising sign) should have a relationship to existing buildings and surroundings.
61 It is also the case that in making its development decisions, the respondent needs to have regard to precinct planning policies and the planning principles contained therein.
62 Having said this, the respondent has been provided with discretionary powers under cl 27(4) and cl 38 of TPS 4 in particular to approve any development that it thinks fit within the broad scope of the Scheme.
63 An examination of the provisions of the Town Centre Policy shows an emphasis on amenity and protecting adjacent residential areas from the impact of development. In that sense the Policy is complementary to TPS 4.
64 The more detailed Advertising Signs Policy outlines a range of signs that are "exempt" from requiring a development approval and also lists a range of signs (including a "pylon sign") which the City would generally not approve.
65 Although there was a difference of view between the parties as to whether the proposed sign is a "pylon sign", the Tribunal believes that the matter of definition is secondary to the need to judge the proposal on its merits. However, the proposed development is certainly not exempt from the approval process.
(Page 17)
66 The Advertising Signs Policy also provides some guidance on the appropriateness of signage with an emphasis on the scale and design being appropriate to the building to which it relates, and to be compatible with the existing surrounding development.
67 On the issue of legislative and policy provisions it is clear that the applicant is essentially advancing a broad "merits-based" argument, rather than one that relies on a strict adherence to statutory detail.
68 This is not an argument with which the Tribunal would necessarily disagree, and was put into context in Drake and Minister for Immigration and Ethnic Affairs (No 2) (1979) 2 ALD 634 when Brennan J confirmed the freedom of the Administrative Appeals Tribunal to apply, or not to apply, policy. He noted however, that departures from government policy should be "cautious and sparing" and only occur where there were "cogent reasons".
69 A similar type reasoning was given in Clive Elliott Jennings & Co Pty Ltd v WAPC (2002) 122 LGERA 433 at [24] where Barker J held that the existence of a policy cannot replace the discretion of the decision-maker in the sense that it is to be inflexibly applied, regardless of the merits of the particular case.
70 He explained though that:
"… the relevant consideration in many applications will be why the 'policy' should not be applied; why the planning principles that find expression in the 'policy' are not relevant to the particular application."
71 Within the City of Subiaco it can be said that the matter of Advertising Signs has been elevated to the policy level, and it appears that some progress is being made in the locality of the subject land to advance the policy provisions.
72 That is to say that from the photographic evidence and attached comment provided by Mr Clairfayt in his witness statement, it appears that no signage was allowed on the three-storey commercial premises at 418 Hay Street directly opposite the Forrest Street and Railway Road junction. Also, there is no signage at 105 Railway Road next door (west) to the subject land and only a somewhat discreet wall sign on the two-storey commercial development at nearby 47 Forrest Street to the east and at the single storey former residence at 51 Forrest Street to the east.
(Page 18)
73 It is of course possible that inconsistencies to policy are present within the local government area (such as the projecting sign over the footpath at 109 (107) Railway Road) but this is not of itself a reason to grant an approval in this case.
74 A further factor is that although there are several commercial premises in Forrest Street towards Railway Road, the majority of development on the south side of Forrest Street and west of Denis Street is residential. There are also a number of dwellings on the north side of Forrest Street west of Denis Street.
75 That is to say that the Tribunal would argue that the scale of the sign at 4.5 metres high is incompatible with the residential component of the surrounding development in particular, but also incompatible with the signage on nearby commercial premises. In that sense the proposed signage would not preserve the existing amenity of the immediate locality.
76 One point that the Tribunal would acknowledge is that the building on the subject land is positioned 14.5 metres back from the front boundary and any signage on the building itself could be difficult to see from some angles. One way to overcome this difficulty would be construct a low front boundary wall with signage similar to the ProCol sign directly opposite at 99 Railway Road. This would also have the effect of minimising the open nature of the carpark at the front of the site.
77 On balance the Tribunal believes that the proposed advertising sign at 4.5 metres high would be incompatible with the nearby residences and would be inconsistent with existing signage on commercial developments nearby. It would be contrary to the intent of the Advertising Signs Policy.
78 Accordingly, it is the view of the Tribunal that the proposal is both contrary to orderly and proper planning and the preservation of the amenity of the locality and that an approval could give rise to similar-type developments elsewhere in the City. If that was to occur it could lead to an undermining of the Advertising Signs Policy.
Order
79 For the foregoing reasons, the orders of the Tribunal are:
1. The application for review is dismissed.
(Page 19)
I certify that this and the preceding [79] paragraphs comprise the reasons for decision of the State Administrative Tribunal.
___________________________________
MR L GRAHAM, SENIOR SESSIONAL MEMBER
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