El-Hachem v Bankstown City Council
[2014] NSWLEC 1039
•05 March 2014
Land and Environment Court
New South Wales
Medium Neutral Citation: El-Hachem v Bankstown City Council [2014] NSWLEC 1039 Hearing dates: 23-24 February 2014 Decision date: 05 March 2014 Jurisdiction: Class 1 Before: Morris C Decision: Appeal upheld
Catchwords: Development application: Villas, SEPP 1 objection, amenity Legislation Cited: Bankstown Local Environmental Plan 2001; State Environmental Planning Policy No 1 - Development Standards; Environmental Planning and Assessment Act 1979 Cases Cited: Wehbe v Pittwater Council [2007] NSWLEC 827 Texts Cited: Bankstown Development Control Plan 2005 Category: Principal judgment Parties: Joseph El-Hachem (Applicant)
Bankstown City Council (Respondent)Representation: Mr P Clay SC (Applicant)
Mr A Seton
Mr V Conomos
Conomos Legal (Applicant)
Marsdens Law Group (Respondent)
File Number(s): 10628 of 2013
Judgment
Mr El-Hachem lodged Development Application 676/2011 (application) with Bankstown City Council seeking consent to demolish an existing dwelling house and associated outbuildings and construct four villa homes with strata subdivision. The council refused consent and El-Hachem is appealing that decision.
The issues with the case are whether the development breaches a development standard and if it does, whether it is appropriate to vary that development standard and if the amenity of the proposed dwellings is satisfactory or the proposal represents an overdevelopment of the site and has unreasonable impacts on neighbouring properties.
The site and locality
The site is Lot 101 in Deposited Plan 599164 and known as No. 82A Highclere Avenue, Punchbowl. It is an irregular battle-axe allotment located on the western side of the roadway with a 3.6m frontage to Highclere Avenue.
The southern boundary of the access handle measures 44.585m in length with the access handle varying in width from 3.6m to 6.2m. The total site area is 1415sqm and the area of the site, according to the survey lodged with the application and Exhibit D in the case, is 1201.5sqm excluding the access handle, with the measure taken perpendicular to the northern boundary rather than the prolongation of the eastern boundary. The site would be less if the latter dimension was used, some 2sqm less. That handle runs at an angle to the road and follows the line of an adjoining drainage easement that runs along the entire northern boundary of the site and provides a pedestrian link from Highclere Avenue to Henry Street.
The site contains a single storey brick dwelling and detached outbuildings and slopes from the south-western corner to the north east and Highclere Avenue. A 0.914m wide easement to drain water extends along the site's western boundary. Vegetation comprises a mix of native and exotic species, the majority of which are proposed to be removed however, the applicant advises that it would be possible to retain at least 6 trees, two along the northern boundary, two along the southern and two at the rear of the site. Amended consent conditions have been prepared to reflect this action.
The site is subject to an overland stormwater flowpath that requires the floor levels of any dwellings to be elevated above flood level. The council has prepared conditions that should be attached to any consent issued so as to address that constraint.
Immediately to the south of the site is a townhouse development with its driveway running along the common boundary of the site and the adjacent property to the east, No. 82 Highclere Avenue. That property contains a single storey dwelling house and originally formed part of the same allotment before the battle-axe subdivision occurred. Two, two-storey dwellings are located to the north of the site, also in battle-axe configuration with a mix of one and two storey dwellings opposite and to the rear of the site. There are also townhouse and villa house developments further to the north and south of the site.
Background and the proposal
The original application was lodged with the council on 4 August 2011 and has been modified on a number of occasions. Following a conciliation conference the application was granted leave to rely on amended plans and it is those plans that are now before the Court. The proposal involves demolition of all existing buildings on the site and the construction of four villa houses in two buildings that run north/south along the site and front a central driveway. Dwellings 1 and 2 contain a living area, kitchen, bedroom, bathroom, laundry and double garage on the ground floor and two bedrooms in a loft arrangement within the roof area. Villas 3 and 4 comprise living, kitchen, bathroom, 2 bedrooms and tandem garages on the ground floor and 2 bedrooms and bathroom in the loft. The living areas of the villa houses open onto a private courtyard and, in the case of villas one and two an elevated deck area provides access to that space.
The council refused consent on 5 March 2013 on three grounds:
(1) The development does not comply with the frontage requirements of Bankstown Local Environmental Plan 2001 Clause 46(3)(b).
(2) The development does not comply with Bankstown Development Control Plan 2005 Part D2 Residential Zones Clause 10.17(e), as the proposal fails to provide for more than one 75 litre tree between a building and the primary frontage.
(3) Due to the above reasons, and the objections received during the neighbour notification period, the proposal is not considered to be in the public's wider interest.
The planning controls
The site is zoned Residential 2(a) under Bankstown Local Environmental Plan 2001 (LEP). Villa house development is permitted with consent in that zone, subject to compliance with other clauses of the LEP.
Clause 11 of the LEP requires the consent authority to have regard to the general objectives of the plan and objectives of the zone and other relevant provisions of the plan when determining whether consent should be granted to an application. The objectives of the LEP are contained in clause 2 as follows:
(a) to regulate development in accordance with the following principles:
(i) new buildings should be designed to achieve:
(A) good urban design, and
(B) public and private safety, and
(C) energy and resource efficiency, and
(ii) remnant bushland, natural watercourses and threatened species should be protected, and
(iii) intensive trip generating activities should be concentrated in locations most accessible to rail transport, and
(iv) new development should not diminish the role of the Bankstown central business district (CBD) as a sub-regional centre, and
(v) new development in or affecting residential areas should be compatible with the prevailing suburban character and amenity of the locality of the development site, and
(b) to provide a framework within which the Council may prepare development control plans to make more detailed provisions.
The objectives of the Residential A zone are:
(a) to complement the single dwelling suburban character of the residential areas of Bankstown City, and
(b) to enable dual occupancy, rowhouse and villa development that is otherwise consistent with the objectives of the zone, and
(c) to ensure that sites are of sufficient size to provide for buildings, vehicular and pedestrian access, landscaping and retention of natural topographical features, and
(d) to ensure that development is of a height and scale which complements existing buildings and streetscapes (noting that 2 storey dwellings may occur throughout residential areas), and
(e) to allow for some non-residential use that would not adversely affect the living environment or amenity of the area, and
(f) to encourage energy efficiency and resource conservation measures in the design, construction and occupation of residential buildings, and other buildings permitted in this zone, and
(g) to ensure adequate public and private open space is available to residents, and
(h) to require satisfactory drainage, and
(i) to require landscaping of development sites.
In residential zones, pursuant to the provisions of clause 45 of the LEP, consent may be granted only if it would be compatible with the character and amenity of existing and likely future buildings on adjoining land in terms of:
(a) its scale, bulk, design, height, siting and landscaping, and
(b) its operation, and
(c) traffic generation and carparking, and
(d) noise, dust, light and odour nuisance, and
(e) privacy, and
(f) stormwater drainage, and
(g) hours of operation, and
(h) overshadowing.
Core residential development standards are contained in clause 46. The objectives of those standards, which apply to all forms of residential development including subdivision, are:
(a) where an existing allotment is inadequate in terms of its area or width, to require the consolidation of 2 or more single residential allotments for villa development or residential flat buildings, to achieve the other objectives in this subclause, and
(b) to ensure that allotments are of sufficient size to accommodate proposed dwellings, setbacks to adjoining residential land, private open space and courtyards, driveways, vehicle manoeuvring areas and the like, and
(c) to ensure that the site of a proposed villa development is of adequate area and width to enable that development to be arranged without long lengths of walls in a straight line, and
(d) to limit the potential for villa, rowhouse, terrace house and dual occupancy development in Zone 2 (a), and
(e) to ensure that dual occupancy, rowhouse or villa development in Zone 2 (a) retains the general low-density scale and character of existing single dwelling development.
The development standards for villa development are contained in subclause (3) which states:
(3) The consent authority is not to grant consent to development for the purpose of villas on an allotment of land within Zone 2 (a) or 2 (b) unless:
(a) the allotment has an area of 1,200 square metres or more, and
(b) the allotment is at least 20 metres wide at the front building line, and
(c) the site area per villa (excluding the area of access handles or rights of way for access) is not less than 300 square metres.
It is common ground that the site complies with the provisions of subclauses (3)(a) and (c) however, it is not agreed whether the site is at least 20m wide at the front building line.
The Dictionary to the LEP is contained in Schedule 1. In this clause front building line means the line determined by the Council establishing the minimum setback of a building from the street alignment. In the case of an allotment with frontage to more than one street, the front building line applies to the shortest frontage. Other than the provisions of clause 2(b), the LEP does not contain details on how this line is established.
Bankstown Development Control Plan 2005 (DCP) applies to the site and has the following objectives:
(a) to have a single, dynamic document that supports
Bankstown Local Environmental Plan 2001;
(b) to have objectives and development controls that
establish clear guidelines for development in the
City of Bankstown;
(c) to develop a high quality urban environment and
built form character in the City of Bankstown;
(d) to ensure development contributes to the prosperity
of the City of Bankstown;
(e) to ensure development protects and enhances the
natural environment in the City of Bankstown;
(f) to ensure development incorporates the principles
of ecologically sustainable development; and
(g) to promote a safe and secure environment in the
City of Bankstown.
Definitions are contained in Part C of the DCP and the following are relevant to the application:
Building line (including front building line) means the line between the front boundary of an allotment and the required setback fro the type of development. The building line can apply to the primary frontage and/or the secondary frontage.
Front building line means the line determined by the Council establishing the minimum setback of a building from the street alignment. In the case of an allotment with frontage to more than one street, the front building line applies to the shortest frontage.
The latter is identical to that contained in the LEP.
Part D2 of the DCP - Residential Development is also relevant to the application and includes a statement of desired character for the residential zones. That states:
The prevailing suburban character of the residential zones includes the subdivision pattern, front and side building setbacks, off-street parking behind the front building line and the landscaping of front yards with canopy trees and deep soil plantings.
The desired characters for the residential zones are:
(a) To have a low density residential environment in Zone 2(a) where the typical features are dwelling houses, dual occupancies and villas within a generous landscaped setting. The site cover and building form of development must be compatible with the prevailing suburban character and amenity of this zone. This zone is also the most restrictive in terms of other permitted uses that are considered suitable. These are generally restricted to facilities and services that meet the day-to-day needs of residents.
(b) To have a high density residential environment in Zone 2(b) that provides high density housing (in the form of contemporary designed residential flat buildings) within a landscaped setting. Development should provide appropriate spaces between buildings, communal open spaces and deep soil zones to provide adequate amenity for residents.
Section 8 of Part D2 applies to villas. The objectives of this section of the DCP are:
(a) to ensure the building form, building design and landscaping of villas are compatible with the prevailing suburban character of the residential areas, particularly the single dwelling suburban character of the low density residential areas;
(b) to ensure the building form and building design of villas provide appropriate amenity to residents in terms of private open space, access to sunlight and privacy;
(c) to ensure the building form and building design of villas do not adversely impact on the amenity of neighbouring properties in terms of visual bulk, access to sunlight and privacy;
(d) to ensure the building form of villas in the foreshore protection area preserves the existing topography, land and rock formations, and the unique ecology of natural bushland and
mangrove areas;
(e) to provide adaptable dwellings to cater for the needs of senior residents and residents with disabilities; and
(f) to minimise the visual impact of off-street parking on the streetscape.
Development controls relevant to determination of the application are Setbacks to the primary frontage (8.7); Side and rear boundaries (8.9); Private open space (8.11); Access to sunlight (8.12-15); Visual privacy (8.16-19); Building design (car parking) (8.27-30) and Landscaping (8.32-33).
The issues
The contentions in the case are that the proposal does not comply with the development standard contained in clause 46(3)(b) of the LEP in terms of allotment width at the front building line and that the objection to that development standard, lodged under the provisions of State Environmental Planning Policy No 1 - Development Standards (SEPP1) is not well founded; the development is inconsistent with the objectives of the core residential development standards; the courtyards and decks are of poor design and will provide a low level of amenity for future residents; inadequate solar access to the living areas of villa 2 and the proposal is an overdevelopment of the site.
The evidence
The hearing commence on site and included observation of the property from the adjacent townhouse development to the south and a walk around the immediate locality. Evidence was heard from one of the residents of the adjoining townhouse complex who had lodged objections to the council in relation to the application. The issues raised are summarised as:
- Change to the environment;
- Too close to the boundaries;
- Noise;
- Drainage issues from development upstream of the site;
- Will exacerbate existing parking problems;
- No area available for presentation of garbage bins and existing problems will be exacerbated;
- Concerns about the need to remove trees;
- Wants the environment to stay the way it is;
- Not a unit area.
Expert town planning evidence was heard from Mr A Betros for the applicant and Mr S Layman for the council. They agree that the proposed floor space ratio (FSR) is 0.4:1 which is below the 0.5:1 standard permitted under the LEP. It is common ground that the development complies with all of the relevant numerical controls contained in the LEP and DCP other than those matters detailed in the contentions.
There is no agreement as to whether the development standard for allotment width at the front building line is met. Mr Betros says that the lot width at the front building line is greater than 20m, being approximately 26-27m where the built form is proposed. Mr Layman disagrees and says that the council has made a determination of the front building line when it made the DCP and applied setbacks to the primary and secondary frontages. Clause 8.7 of Part D2 of the DCP provides for the minimum setback for a building to the primary frontage of 5.5m for the first storey and 6.5m for the second storey. As the proposal is for a single storey development with loft the front building line is 5.5m and, in its terms clause 8.7 provides that these distances should be measured from the (street) frontage boundary of the subject site. Whether or not this measurement is made parallel to the front boundary or parallel to the side boundary is of little consequence as the site is about 4m wide, well deficient by approximately 80%.
On a precautionary basis, Mr Betros prepared an objection to the development standard for allotment width which forms part of the Supplementary Statement of Environmental Effect, Exhibit C. Consideration of the objection under SEPP1 is made later in this judgment and also goes to the issue of whether the application is consistent with the objectives of the core residential development standards.
With regard to the amenity of the villa courtyards, Mr Betros says that each of the courtyards and decks are directly accessible from the living areas and comply with or exceed the 60sqm requirement and receive abundant sunlight. The decks measure approximately 2m x 4m which is usable whilst the grassed and landscaped areas are also suitably sized and designed. The internal outlook to the landscaped areas enhances the amenity of the dwellings. In his opinion, the proposed privacy screens along the permitter of the eastern decks to dwellings 1 and 2 are not essential given the extensive distance of separation to the eastern neighbour (approximately 20m) along with the established and additional planting proposed.
During the hearing, the issue of these screens was addressed by the applicant with an alternate treatment proposed to the common boundary fence between the site and No 82 through the addition of 500mm high latticework above the height of the existing 1.8m fence. This would also address the concerns in regard to the amenity of the deck. Mr Layman agreed that this would prevent over viewing No 82 from proposed dwelling No 2 and that the view from dwelling 1 would be restricted to the upper portions of the rear door/windows however says that there is a need to look at the totality of the impact and that if there are impacts they should be avoided. Mr Betros says that this would be sufficient to address any impact due to the separation distance of around 18-20m.
Amended solar diagrams were attached to the joint report, exhibit 4. Mr Betros says that these confirm that villa 2 receives 3 hours solar access between 8am and 3pm on June 21 as required by the DCP. Mr Layman did not challenge that assessment however says that the privacy screens would have compromised this.
The applicant's alternate privacy treatment would remove the shadow impacts and therefore, the solar access provision is met.
Mr Betros says the proposal is not an overdevelopment of the site as the density is 20% below that permissible and the FSR of 0.41:1 is below the lowest density standard that applies to the entire Bankstown local government area (0.5:1). The built form is sympathetic given it consists of a single storey with attic roof form, the internal location of the dormers ensures that the proposal will be perceived as single storey from the surrounding neighbours to the east and west whilst those to the north and south would only have an oblique view to the internal facing dormer windows. The built form is modest in its context, having regard to the two storey townhouses to the south and the two, 2 storey buildings to the north. The retention of and additional tree planting around the permitter and in between the two buildings along the northern and southern boundaries further softens the visual appearance of the built form when viewed from surrounding properties.
Mr Layman says that the permissible density applies across the zone, is the maximum that might be achieved on an ideal site, the site is not ideal because of its battle-axe shape, relationship to adjoining development and its flood affectation so is constrained from achieving the maximum and is not necessarily indicative of a modest development. The flooding constraint requires elevation of the floor levels giving rise to privacy and amenity issues that compromise the resident amenity and development that is not characteristic of the existing single dwelling development.
The experts agree that if the site was consolidated with the adjacent lot No 82 Highclere Avenue, that the combined allotment would have a width at the 5.5m front building line of approximately 19.3m and at 6.5m approximately 19.4m, so would not comply with the 20m development standard for villas however would provide for dual occupancy development which would also be possible on the front allotment without the need to consolidate with the site as a width of 15m is required. Mr Betros advised that attempts to consolidate with that owner had been unsuccessful. They agreed that, due to the location of the site adjoining the townhouse development to the south and the drainage easement to the north, the only other option to consolidate would be with lots to the rear fronting Henry Street and that whilst this was physically possible no approach had been made to the owners. Mr Betros said that the shape of the site consolidated in such a manner would be unusual however Mr Layman did not see it as a constraint.
The SEPP1 objection
As stated at [26-27], Mr Betros has prepared an objection to the development standard for allotment width at front building line on the basis that the Court concludes the site is non-compliant. That objection follows the principles established by Preston CJ in Wehbe v Pittwater Council [2007] NSWLEC 827 and in particular, the first ground where he says that compliance with the development standard is unreasonable and unnecessary in the circumstances of the case because the objectives of the standard are met. His assessment of each objective is detailed in the both the written objection in Exhibit C and the Joint Report, Exhibit 4.
Mr Layman disagrees and says that objectives (a) and (e) are not met because the allotment is inadequate in area having regard to its context to provide appropriate privacy and amenity to residents, particularly dwelling 2 without reliance on privacy measures and the proposal does not exhibit the general low density character of existing single dwelling development. The overland flowpath constrains the ability to landscape the site so does not achieve the generous landscaped setting envisaged by the desired character statement.
Conclusion and findings
Firstly, I must determine whether the development standard for allotment width at the front building line is met. I accept the council's submission that it is not. That is because I agree that the front building line is as determined by reference to the front setbacks contained within the DCP. Clause 2(b) of the LEP states that one of its objectives is to provide a framework within which the Council may prepare development control plans to make more detailed provisions. I consider the fact that the DCP adopts the identical definition of front building line and then further clarifies in the definition of building line that it is the line between the front boundary of an allotment and the required setback for they type of development clarifies that. For the development of villas on the site, the council, through the adoption of the DCP, has determined that the front building line is 5.5m in the circumstances of the case thereby clarifying and providing more detailed provisions on how to apply the development standard in a particular case for a particular type of development. The framework of the development standard has been articulated in the more detailed provisions contained in the DCP. This is consistent with the objectives of the LEP.
Having determined that the development standard is not met because the lot is not 20m wide at the front building line, for the Court, exercising the functions of the consent authority to have power to grant consent to the application, it must uphold the SEPP1 objection to compliance with clause 46(3)(b) of the LEP. Upholding the objection is a precondition which must be satisfied before the application can be approved on a consideration of the merits as required under s79C of the Environmental Planning and Assessment Act 1979 (Act).
In accordance with the guidance in Wehbe and having regard to the provisions of SEPP1, there are three matters which the Court must be satisfied. These are detailed in Wehbe at [38-40] and summarised as follows:
(1) The objection is well founded (clause 7 of SEPP1);
(2) Granting of consent to the application is consistent with the aims of the policy (clause 7);
(3) Consideration of the matters in clause 8(a) and (b) of SEPP1 justify the upholding of the objection.
The applicant submits that compliance with the development standard is unreasonable or unnecessary because the objectives of the development standard are achieved notwithstanding non-compliance with the standard. Preston CJ states in Wehbe at [43]:
The rationale is that development standards are not ends in themselves but means of achieving ends. The ends are environmental or planning objectives. Compliance with a development standard is fixed as the usual means by which the relevant environmental or planning objective is able to be achieved. However, if the proposed development proffers an alternative means of achieving the objective, strict compliance with the standard would be unnecessary (it is achieved anyway) and unreasonable (no purpose would be served).
The objectives of the development standard are found at clause 46(1), and set out at [14]. To determine whether the area or width of the site is adequate or should require consolidation with one or more adjacent residential allotments for villa development, subclause (a) directs the consent authority to ascertaining whether the other objectives of the subclause are achieved.
Having regard to the evidence, I am satisfied that the size of the site is sufficient to accommodate the proposed dwellings. The width of the allotment where the buildings are proposed is at least 26m and depth is over 39m, the setbacks proposed accord to the controls contained within the DCP, the areas set aside for private open space and courtyards comply with or exceed the minimum area required under the DCP, the fact that these areas, in the case of villas 1 and 2 are accessed of a deck, is not, in my opinion an unsatisfactory element of the design and does not adversely affect the use of the private open space areas. Nor, with the inclusion of the proposed lattice screening above the existing eastern boundary fence, are there any unreasonable impacts on adjoining properties. Parking provided meets that required by the DCP and adequate area is available within the site to manoeuvre vehicles so they can enter and leave the site in a forward direction. Accordingly, I am satisfied that objective (b) is met.
It is common ground that the development has been designed so that there are no long lengths of walls in a straight line so objective (c) is also met.
Objective (d) seeks to limit the potential for villa, rowhouse, terrace house and dual occupancy development in Zone 2(a). It is not a prohibition but, in my opinion, rather a clause that reinforces that not all allotments are suitable for these higher density forms of residential development and regard must be had to the quantitative and qualitative development standards and controls. It requires a holistic consideration of the objectives, rather than a singular approach of ascertaining whether compliance with individual controls is achieved. Such an approach shows that, apart from the lot width, all other quantitative development standards and controls contained within the DCP are met. This fact and my conclusion that the site is of sufficient area and width for villa development demonstrates that this particular site is suitable for the proposed purpose and is not one where there is limited or no potential for villa development.
With the benefit of the site view and having regard to Mr Betros' evidence, I agree that the proposal will retain the general low-density scale and character of the existing single dwelling development. The footprint of the two proposed buildings is similar to that of dwellings surrounding the site and the height, bulk and scale is less than that evidenced to the north. The elevated floor is not inconsistent with that of adjoining dwelling houses. For these reasons, I am satisfied that objective (e) is also met.
I then return to objective (a) and am satisfied that consolidation of the site with adjacent land is not required because the other objectives of clause 43(1) are achieved.
For the reasons outlined above, I am satisfied that the objection to the development standard contained in clause 43(3)(b) of the LEP is well founded and compliance with that standard would be unreasonable and unnecessary in the circumstances of the case.
I must now turn to whether the granting of consent is consistent with the aims of SEPP1, that is to provide flexibility in the application of planning controls operating by virtue of development standards in circumstances where strict compliance with those standards would, in any particular case, be unreasonable or unnecessary or tend to hinder the attainment of the objects specified in section 5 (a) (i) and (ii) of the Act. Those objects are to encourage:
(1) the proper management, development and conservation of natural and artificial resources, including agricultural land, natural areas, forests, minerals, water, cities, towns and villages for the purpose of promoting the social and economic welfare of the community and a better environment,
(2) the promotion and coordination of the orderly and economic use of developed land.
Having regard to the evidence and the circumstances of the case, I am satisfied that the granting of consent would be consistent with the aims of SEPP1 and would not hinder the attainment of those objects specified in section 5(a)(i) and (ii) of the Act.
Finally, having regard to the provisions of clause 8 of SEPP1, I am satisfied that non-compliance with the development standard does not raise any matter of significance for State or regional environmental planning and that in the circumstances of the case, there is no adverse impact on the public benefit in varying the control.
It is now necessary to undertake a merit assessment of the application in accordance with the provisions of s79C of the Act. The remaining contentions go to the design of the villas and courtyards, solar access and overdevelopment. I am satisfied that the alternate privacy screen proposed by the applicant and the deletion of the privacy screen around the decks to dwellings 1 and 2 resolves those issues.
Having regard to the evidence, submissions made to the council in response to notification of the application and my findings in relation to the SEPP1 objection, I am satisfied that the application is consistent with the provisions of the LEP and DCP; that the impacts of the proposed development, in particular in relation to privacy and solar access are acceptable, that adequate amenity is available to the proposed dwellings and occupants of adjoining sites; the site is suitable for the proposed development and the development would be in the public interest. It is also compatible with the character and amenity of existing and likely future buildings on adjoining land.
The Orders of the Court are:
(1) The appeal is upheld.
(2) Development Application 676/2011 for demolition of an existing dwelling house and associated outbuildings and construction of four villa homes with strata subdivision is approved subject to conditions in Annexure 'A'.
(3) The exhibits, other than exhibits A, C, E and 1, may be returned.
__________________
Sue Morris
Commissioner of the Court
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Decision last updated: 06 March 2014
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