Lowther v Brisbane City Council
[2011] QPEC 152
•22/12/11
PLANNING & ENVIRONMENT COURT
OF QUEENSLAND
CITATION:
Lowther v Brisbane City Council [2011] QPEC 152
PARTIES:
RIDWAN LOWTHER
(Appellant)v
BRISBANE CITY COUNCIL
(Respondent)FILE NO:
BD877/2011
DIVISION:
PROCEEDING:
Appeal
ORIGINATING COURT:
District Court
DELIVERED ON:
22/12/11
DELIVERED AT:
BRISBANE
HEARING DATE:
17/11/11 – 18/11/11
JUDGE:
Searles DCJ
ORDER:
Appeal allowed
CATCHWORDS:
Demolition Control Precinct – Pre 1946 house – City Plan 2000 - Whether Positive Contribution to the Visual Character of Street
COUNSEL:
Appellant: Mr S Ure
Respondent: Mr T Trotter
SOLICITORS:
Robert Milne Legal
Brisbane City Legal Practice
Nature of Appeal
The appellant appeals pursuant to s 461 of the Sustainable Planning Act 2009 (SPA) against the refusal by the Council of a Development Application dated 14 September 2010 for a preliminary approval for building work for the demolition of a house in a Demolition Control Precinct (DCP) and a Material Change of Use for a multi-unit dwelling (six dwelling units) on land situated at 484 Wynnum Road, Morningside, Brisbane. The Council advised the appellant by letter dated 25 October 2011 that the Council had no issue in respect of the multi-unit dwelling component of the application and the only grounds of refusal related to the demolition component. Those grounds are:-
“(1)The Proposal does not comply with P1 and A1.4 of the Demolition Code, as the house
(i)is a recognizable example of a pyramid roof bungalow where minor modifications/alterations to the original fabric could be removed
(ii)no engineering report has been submitted to demonstrate the house is structurally unsound
(iii)the house is representative of ‘traditional timber and tin’ building character
(iv)there are many examples of pre-1946 house styles in that part of Wynnum Road
(2)Demolition of this house will result in the loss of a traditional pre-1946 house in the Demolition Control Precinct and is in conflict with the Purpose of the Demolition Code which is to:
(i)protect residential buildings that represent traditional building character and amenity in a Demolition Control Precinct; and
(ii)ensure the preservation of buildings where they form an important part of a streetscape where constructed prior to 1946
(3)The proposed demolition of the pre-1946 house is in conflict with the Purpose of the Residential Design – Low, Character and Low-Medium Density Code which is to retain pre-1946 dwellings in Demolition Control Precincts.”
The Subject Property
The subject property at 484 Wynnum Road, Morningside contains lots 56 and 57 on RP 12840, comprises an area of 989 m2 and is situated within the Low-Medium Density Residential Area Classification and within a Demolition Control Precinct within the City Plan.
The property fronts Wynnum Road and is some four kilometres east of Brisbane City. Wynnum Road currently has traffic volumes of approximately 27,574 vehicles per day, 10.9% of which (3,005) being heavy vehicles. The 2021 forecast traffic volume is 31,160 vehicles per day of which 11.9% (3,708) will be heavy vehicles.[1]
[1]Exhibit 1, tab 3, p 157, s. 5.1.1 – Carter Rytenskild Group Environment Noise Impact Report, 30 July 2010 lodged with application.
The relevant section of Wynnum Road runs from just east of the Riding Road Intersection to the Jack Flynn Memorial Drive (with a railway bridge to Waminda Street Intersection). On the southern side of Wynnum Road is the Balmoral Cemetery and an RSL Club. On the northern side there are eighteen buildings of the following categories:-
(a) Eight timber and tin pre-1946;
(b) One asbestos cement house;
(c) One post-1946 house;
(d) One pre-1946 house (No. 452) not in the DCP; and
(e) Seven unit blocks of brick or masonry construction.
Details of each property, with a description by each of the two expert witnesses Mr. Veal and Mr. McDonald ,[2] are set out Schedule A.
Immediately to the east of the property is a service station and a tyre fitting outlet and the Morningside Railway Station.
[2]See also report, Mr Veal for appellant, Exhibit 4, p 46 – Aerial Photograph of Individual Properties; Report Mr.McDonald Exhibit 6 pp 22-29
Submitters
There were three submitters note Exhibit 1, tabs 9, 10 and 11 none of whom proposed the demolition application.
Statutory Regime
The City Plan 2000[3] provides for code assessment, the relevant Code comprising the purpose, Performance, Criteria and Acceptable Solutions.[4] The construction of the code should take place against the background of the City Plan of which it forms part in the Residential Neighbourhoods section.[5] The key issue raised by the community in the preparation of the City Plan was described as the desire to protect the City’s unique character. The response to the challenge of which that key issue forms part is described in these terms:-[6]
[3]Chapter 3, p 10, para 1.
[4]City Plan, ch 3, p 9, last paragraph.
[5]Exhibit 2, p 15, 4.2.1, last paragraph.
[6]Exhibit 2, p 16, 4.2.2.4.
“In older suburbs, the unique character is derived mainly from the topography, urban layout and ‘timber and tin’ architecture. ..
..
..
..
Demolition control precincts are those locations in older suburbs that contain pre-1946 housing with distinctive traditional architecture.”
In the Residential Areas Provisions[7] is provided:-
“…different Residential Areas reflect different living environments envisaged in different parts of the City. Accordingly, the scale and intensity of built form will vary between the areas and Council will regulate development through…..controls on demolition or removal of pre-1946 houses.
An important characteristic of the City’s older suburbs is the traditional architecture. Demolition Control Precincts are locations in the older suburbs where pre-1946 housing is still dominant. Specific provisions apply in the Demolition Control Precincts to preserve and compliment much of this architectural character……”
[7]Exhibit 2, ch 3, p 27.
The Intent for the Low Density Residential Area, in which the subject property is located, provides:-[8]
[8]Exhibit 2, ch 3, p 29.
“Groups of buildings in the Low Density Residential Area are included in Demolition Control Precincts. In these locations pre-1946 housing will be retained and new development will reflect pre-1946 architectural character.”
Desired Environmental Outcome (DEO) 3 for that Area Provides:-
“(3)In Demolition Control Precincts pre-1946 buildings are largely retained and new buildings reflect many of the Precincts’ Architectural themes.”
DEO 2 for the Character Residential Area provides:-[9]
“(2)High quality, intact traditional housing is protected. Limited new houses, single unit dwellings and multi-unit dwellings are accommodated that compliment traditional housing form.”
[9]Exhibit 2, ch 3, p 34, para 5.3.2.
DEO 4 the Low-Medium Density Residential area provides:[10]
“(4)In Demolition Control Precincts pre-1946 buildings are largely retained and new buildings reflect many of the Precincts’ Architectural themes.”
[10]Exhibit 2, ch 3, p 34, para 5.4.2.
The relevant provisions relating to codes, and the Demolition Code specifically, are:-
“ The Codes
1 Introduction
This chapter provides details of Codes used in assessment. The Codes give guidance on specific areas of development that apply to different Areas or types of development …
1.1 How to use the Codes
…
Performance Criteria and Acceptable Solutions
...
For code assessment a proposal that complies with all Acceptable Solutions will be approved.
…
The Performance Criteria are in the left hand column of the Code table. They provide a statement of the outcome that the Acceptable Solution must achieve. A proposal not complying with an Acceptable Solution must provide sufficient information to demonstrate how the corresponding Performance Criterion has been met.
…
For Code Assessment
The Acceptable Solutions represent the preferred way of complying with the Performance Criteria. There may be other ways of complying with the Performance Criteria while still meeting the Code’s Purpose. It is the responsibility of the applicant to demonstrate how alternative solutions comply with the Code’s Performance Criteria. A proposal that fails to comply with the Performance Criteria, except in insignificant details, will be refused where it cannot be conditioned to mitigate impacts
…[11]
[11]Ex 2, page 52
The Demolition Code
Demolition Code
1 Application
This Code will apply in assessing building work for the demolition … of a building where:
•on a site in the Demolition Control Precinct where any part of the residential building was substantially constructed in or prior to the end of 1946, or
•where the building was substantially erected prior to 1 January 1900
3 Purpose
The purpose of this Code is to:
•protect the residential buildings that give the Residential Areas in the Demolition Control Precinct their traditional character and amenity
•protect the non-residential character buildings in the Demolition Control Precinct that contribute to the general character of the locality and provide or have provided a variety of services to the community.
•ensure the preservation of non-residential character buildings or structures where they form part of a character streetscape.
•ensure the preservation of buildings where they form an important part of a streetscape where the buildings and streetscape were constructed and/or established in or prior to the end of 1946
•ensure the contribution of houses constructed prior to the end of 1946 that reflect design styles and materials other than ‘timber and tin’ architecture is recognised and retained in the Lower Density Residential Area and Character Residential Area
•in conjunction with the Residential Design-Small Lot Code, ensure that houses moved onto small lots are consistent with the requirements for houses on small lots.
•allow demolition or removal of post-1946 residential building or structurally unsound buildings
•retain traditional commercial character buildings
•In conjunction with the Residential Design-Character Code, ensure that precincts of houses constructed in or prior to the end of 1946 are retained and redevelopment in those precincts complements the houses constructed in or prior to the end of 1946
•retain low cost housing in the form of boarding houses
4.Assessment Guidance – an explanation of traditional building character
Street Context
The traditional scale of a street was first established by its subdivision pattern of 16, 24 or 32 perch lots, with 10, 15 or 20 m frontages respectively. This pattern was reinforced by the traditional building form of a single level house elevated on stumps. This created a reasonably uniform scale, accentuated by consistent stepping of the levels of adjoining buildings in Brisbane’s hilly suburbs, and by uniform spacing between houses in the flatter suburbs.
Building form and scale
The predominant traditional building form of pre-1946 housing is a solid core with attached or integrated verandahs raised above the ground on timber supports. Enclosed areas under houses generally maintain the street appearance of lightweight supports to upper floors and reflect the layout of upper floor verandahs. The roof forms are medium pitched pyramids, hips or gables. This style is often referred to generically as the Queensland vernacular. Other traditional building forms also exist, exhibiting overseas architectural influences on Brisbane’s residential design. These building forms occurred primarily during the inter war period. These styles include, but are not limited to, Art Deco, Spanish Mission, Californian Bungalow and Georgian.
Materials and details
The character of the older suburbs is influenced by elements such as eaves, sunhoods, verandahs, lattice screens and batten panels that cast shadows and provide three-dimensional effects. Character is also derived from the relatively limited range of materials available at the time of construction. This provided a unifying theme of painted timber walls and corrugated steel roofing. These lightweight external elements reduce building bulk and form a transition with the external landscape. They make an appropriate response to the local climatic conditions of strong sun and high rainfall.
Whilst ‘timber and tin’ are the predominant materials of the older suburbs.[sic] The presence of other distinctive building forms, such as the Spanish Mission, and their variety of materials highlights the overseas influence on residential design in Brisbane and is a part of the traditional building character. These housing styles are usually rendered on the exterior and have a base material of fibro, masonry or concrete with a tile or tin roof.
Setting
The traditional setting of houses in the older suburbs is a fairly uniform building line, with individual front gardens punctuated by a pedestrian path and a single width driveway. The setting of the building on the site is also important, particularly in terms of the setbacks provided to existing or proposed side boundaries …
5.Performance Criteria and Acceptable Solutions
Performance Criteria
Acceptable Solutions
Where a residential building:
Where a residential building:
P1 The building:
• Must not represent traditional building character, or
• Must not be capable of structural repair, or
• Must not contribute positively to the visual character of the street
Note: ‘Traditional Building
Character’ is described in Section 4 of this CodeA1.1
A1.2
A1.3
A1.4
The building has been substantially altered and/or does not have the appearance of being constructed in or prior to 1946 OR
An engineering report must be submitted demonstrating that the building is structurally unsound and not reasonably capable of being made structurally sound
ORThe demolition of a building will not result in the loss of:
• traditional building character within the Demolition Control Precinct where in a Low Density Residential Area or Character Residential Area or,
…
• traditional ‘timber and tin’ building character within the Demolition Control Precinct where in a Low-medium Density Residential AreaOR
The street has no traditional
building character……. …… Where a building built prior to 1900 P7 The building must not be capable of structural repair A7.1 An engineering report must be submitted demonstrating that the building is structurally unsound and not reasonably capable of being made structurally sound
Issues
It is agreed that issues to be determined contained in the relevant provisions of the Demolition Code in Schedule A:-
(a) Performance Criteria P1, first and third dot points only (building must not represent traditional building character or must not contribute positively to the visual character of the street);
(b) Acceptable Solution A1.3 second dot point only (demolition will not result in the loss of traditional “timber and tin” building character within the Demolition Control Precincts where in a Low-medium Density Residential Area); and
(c) Acceptable solution A1.4 (the street has no traditional building character);
(d) Of the Purpose of the Code only the first, fourth and ninth dot points are relevant.
It is accepted by both parties that the performance criteria and Acceptable Solutions in s. 5 of the Demolition Code contain alternative and not cumulative requirements so that it is sufficient for the appellant to satisfy either the first or third dot point of P1 or any one of the Acceptable Solutions A1.3 second dot point or A1.4[12]for the Appeal to succeed.
[12]Ken Ryan & Associates Pty Ltd v Brisbane City Council & Ors [2008] QPELR 147 at para 12, Litbit Pty Ltd v Brisbane City Council [2008] QPELR 74 at para 7; and Hearne v Brisbane City Council [2010] QPEC 16 at para 20.
Appellant’s Position
The appellant’s position is that:-
(a) The building:-
(i) Does not represent traditional building character;
(ii) Does not contribute positively to the visual character of the street;
(b) The demolition of the building will not result in the loss of:-
(i)Traditional timber and tin building character within the DCP in the Low Medium Density Residential Area;
(c) The street has no traditional building character.
Council’s Position
The Council’s position is that the proposed demolition conflicts with the Demolition Code in that:-
(a) The building:-
(i) Does represent traditional building character;
(ii) Does contribute positively to the visual character of the street.
(b) None of the relevant Acceptable Solutions are satisfied in that:-
(i) The building has not been substantially altered and: does have the appearance of being constructed in or prior to 1946;
(ii) The demolition will result in the loss of “traditional timber and tin” building character within the Demolition Control Precinct wherein a Low-Medium Density Residential Area;
(iii) The street has traditional building character;
(iv) The Council further says that the proposed demolition will be in conflict with dot points 1, 4 and 9 of the Purpose of the Demolition Code.
Expert Evidence
Both parties called experienced heritage architects Mr Basil Veal (appellant) and Mr Ivan McDonald (Council). Both experts provided individual reports[13] and they also provided a joint report[14] following upon a meeting on site on 7 September 2011.
[13] Veal, August 2011, Exhibit 4; McDonald, 14 November 2011, Exhibit 6.
[14]Exhibit 3, 27 September 2011.
Points of Agreement between Experts
Relevantly the experts agreed upon the following[15]:-
[15]Exhibit 3, pp 1-2.
(a) The building was built pre-1946 and is a residential building in a Low-Medium Density Residential Area and in a Demolition Control Precinct within City Plan;
(b) Matters of character are generally relevant;
(c) The extent of the relevant DCP covers that part of Wynnum Road from number 436 to 498-500;
(d) The building forms part of the Wynnum Road landscape;
(e) The relevant part of Wynnum Road for the purpose of assessing the visual character of the street is as above for the consent of the DCP; and
(f) The demolition code is the only applicable code.
Points of Disagreement between the Experts
The experts disagreed on the following issues:-[16]
[16]Ibid, pp 3-7.
(a) Whether the building represents “traditional building character”;
(b) Whether the building contributes positively to the visual character of Wynnum Road;
(c) Whether demolition of the building would protect the residential buildings that give the Residential Areas in the DCP their traditional character and amenity (dot point 1 of Demolition Code Purpose);
(d) Whether demolition of the building would ensure the preservation of buildings where they form an important part of a streetscape where the buildings and streetscape were constructed and/or established in or prior to the end of 1946 (Demolition Code Purpose dot point 4);
(e) Whether the demolition of a building would ensure that precincts of houses constructed in or prior to the end of 1946 are retained and redevelopment in those precincts compliments the houses constructed in or prior to end of 1946 (Demolition Code Purpose dot point 9).
(f) Whether the building represents traditional building character; and
(g) Whether the building contributes to the visual character of the street.
Performance Criteria P1 – Building Must Not Contribute Positively to the Visual Character of the Street
As I have said the experts have agreed that the relevant part of Wynnum Road for the purposes of streetscape analysis is that section between numbers 436 and 500. In the joint report Mr Veal expresses the view that the building does not contribute positively to the visual character of Wynnum Road because:-
(a) The subject streetscape has been irreversibly altered because of the demolition of six pre-1946 houses, relocation of a house from another block to 400 Wynnum Road and the construction of seven post-1946 home unit blocks. This has resulted, in his view, in a fragmented streetscape consisting of a mixture of pre-1946 houses in the minority, one post-1946 house, seven new post-1946 home unit blocks and one relocated house. Of the eighteen buildings in the relevant area less than two thirds are pre-1946 houses. In Mr Veal’s view the subject house could not be said to be a dominant feature of a pre-1946 streetscape now dominated by home unit blocks.[17]
[17]Joint report, Exhibit 3, para 16.1; Veal report, exhibit 4, para 4.2.
Mr McDonald’s View
As opposed to that Mr McDonald expressed the opinion that the subject building does positively contribute to the visual character of Wynnum Road. For these reasons:-
(a) The subject building has a fairly uniform building line with the majority of the street;
(b) It is fairly uniform in height scale and form with the majority of the street and sits with a visually related group of pre-1946 houses and a sympathetic post-1946 building;
(c) The street contains a predominance of pre-1946 houses which contribute positively to the visual character of the street;
(d) Other nearby post-1946 buildings are sympathetic to traditional building character and also contribute positively to the visual character of the street;
(e) The street was well established prior to 1946 and retains sufficient pre-1946 houses for it to reasonably be described as exhibiting a traditional building character. The subject building is one of these pre-1946 houses; and
(f) The subject building is sufficiently intact to continue contributing positively to the traditional building character of the street in a manner similar to how it has always done.
Finding Re A Positive Contribution to the Visual Character of the Street
In Lonie v Brisbane City Council[18]. His Honour Skoien SDCJ said:-
“In a case such as this in which the determining features are such concepts as building character, tradition, style and aesthetics, I have to keep firmly in mind that I must act on the evidence, not my own opinions on such things. In particular, I must remember that a view [which I had] is not evidence, but merely an aid to the understanding of the evidence”
[18] [1998] QPELR 209 at 210.
Mindful of his Honour’s caution, I have considered all the evidence on this issue and been assisted in understanding it by the view I had of the property and the relevant part of Wynnum Road. I have no hesitation in saying I prefer the evidence of Mr Veal on this issue. Whatever pre-1946 character this part of Wynnum Road had, I am of the view that it has lost it and that, consistent with Mr Veal’s view, the streetscape is now dominated by the intrusion of the home unit development. The building does not, in my opinion, contribute positively to the visual character of the street. Given my finding on this issue there is no need to deal with the other issues.
Order
I accordingly order that the appeal be allowed.
SCHEDULE A
Description of Streetscape Properties by each Expert
MR VEAL (Appellant)
| (i) | 500 Wynnum Road Photo 1, p.9 | Unit Block | Masonry walls and tiled roof and vertically sheeted screen fence with visible air conditioner. |
| (ii) | 498 Wynnum Road | Unit Block | Painted masonry, tiled roof, visible a/c |
| (iii) | 492 Wynnum Road | Unit Block | Masonry walls, iron roof, visible a/c’s, high screen fence |
| (iv) | 484 Wynnum Road Photos 1-4, pp.6 and 7 | Pre 1946 house | The subject property |
| (v) | 482 Wynnum Road Photo 6, p.11 | Pre 1946 house | Altered, extended and built in underneath. Non original upper windows. High screen fence behind hedging |
| (vi) | 478 Wynnum Road Photo 7, p.12 | Asbestos cement pre 1946 house | Not timber and tin, not character, high screen fence |
| (vii) | 472 Wynnum Road Photo 8, p.12 | Unit Block | Recent masonry, colour bond roof, masonry screen fence |
| (viii) | 468 Wynnum Road Photo 9, p.13 | Unit Block | Comprising post 1946 house, multi paned casement windows, high screen fence and recent additional unit structure |
| (ix) | 464 Wynnum Road | Unit Block | Brick, visible a/c, high screen fence |
| (x) | 462 Wynnum Road | Post 1946 house | High screen fence. |
| (xi) | 460 Wynnum Road | Pre 1946 house | Recent style, high popes head screen fence |
| (xii) | 456 Wynnum Road | Pre 1946 house | Louvre enclosed verandah |
| (xiii) | 452 Wynnum Road | Pre 1946 house | Vinyl or siding cladding not in the DCP |
| (xiv) | 446 Wynnum Road | Unit Block | Multi storey brick |
| (xv) | 442 Wynnum Road | Pre 1946 house | Old Queenslander style, non-compatible CCA treated pine fence |
| (xvi) | 440 Wynnum Road | Pre 1946 house | Enclosed front verandah with louvres |
| (xvii) | 438 Wynnum Road | Pre 1946 house | Altered single gable |
| (xviii) | 436 Wynnum Road | Pre 1946 house | Old Queenslander, traditional paling fence |
MR MCDONALD (Council)
| Address in Wynnum Road | Description of Property |
| 498-500 | Apartment building circa 1990s. Rendered masonry walls, tile roof. Medium pitch hip. Unsympathetic modern building. Not in a DCP. |
| 488-492 | Apartment building 1-2 storey circa 2000s. Bagged and painted brick walls, corrugated iron roof. Medium pitch hips and gables. Sympathetic modern building. Not in a DCP |
| 484-486 | Mid-set (at street) house circa 1910s. Weatherboard walls, corrugated iron roof, medium pitch pyramid roof. Pre-1946 “timber and tin building character”. In a DCP. |
| 482 Wynnum Road | Mid-set (at street) house circa 1910s. Chamferboard walls, corrugated iron roof with medium pitch hip. Pre-1946 “timber and tin building character”. In a DCP. |
| 478 Wynnum Road | Low-set (at street) house circa 1930s. Fibro walls, corrugated iron roof with medium pitch hip. Pre-1946 fibro and tin building character. In a DCP. |
| 472-474 | Apartment building, two storeys, circa 1990s rendered masonry walls. Corrugated iron roof with medium pitch hip and gables. Sympathetic modern building not in a DCP. |
| 468 Wynnum Road | Low set (at street) house with two modern apartments at rear circa 1950s (house). Weatherboard walls, corrugated iron roof with medium pitch hip. Post-1946 timber and tin building character. Not in a DCP. |
| 464 Wynnum Road | Apartment building two-storeys. Circa 1970s. Face brick walls, medium deck flat roof. Unsympathetic modern building. Not in a DCP. |
| 462 Wynnum Road | High-set house, circa 1970s. Chamferboard walls and tile roof with medium pitch gable. Somewhat sympathetic modern building. Not in a DCP. |
| 460 | Lowset (at street) house circa 1910s. Weatherboard walls, corrugated iron roof with medium pitch hip and gable. Pre-1946 “timber and tin” building character. In a DCP. |
| 456-458 Wynnum Road | Low-set (at street) house circa 1910s, chamferboard walls, corrugated iron roof with medium pitch hip and gable. Pre-1946 “timber and tin” building character. In a DCP. |
| 452-454 Wynnum Road | Two-storey house, circa 1930s. Vinyl (?), chamferboard walls, decramastic tile roof with medium pitch gables. Somewhat sympathetic pre-1946 building character. Not in a DCP. |
| 446 | Three-storey apartment building, circa 1970s, face brick walls with flat metal deck roof. Unsympathetic modern building. Not in a DCP. |
| 442 | Low-set (at street) house. Circa 1910s. Chamferboard walls. Corrugated iron roof with medium pitch hip. Pre-1946 “timber and tin” building character in a DCP. |
| 440 | Low-set (at street) house, circa 1930s. Weatherboard walls with corrugated iron roof with medium pitch gables. Pre-1946 “timber and tin” building character. In a DCP. |
| 438 Wynnum Road | Low-set (at street) house, circa 1920s. Chamferboard walls, corrugated iron roof with medium pitch hip and gable. Pre-1946 “timber and tin” building character. In a DCP. |
| 436 | Low-set (at street) house circa 1910s. Chamferboard walls, corrugated iron roof with medium pitch hip. Pre-1946 “timber and tin” building character. In a DCP. |
| 441 Balmoral Cemetery, Heritage Place | Treed open space and cemetery. Not in a DCP. |
| 481 Balmoral Park, Heritage Place | Treed – open space. Not in a DCP. |
| Part of 481 Morningside Services Club | One-storey building, circa 2000s. Glass, rendered walls, metal deck roof with curved porte-cochere (at front) and flat (behind). Treed, open space and modern building in heritage listed park. Not in a DCP. |
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