material change of use - holiday accommodation, … · holiday accommodation units, prescribed...

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Agenda – Ordinary Meeting 9/12/09 #2330671

ORDINARY MEETING

9 DECEMBER 2009

28 MATERIAL CHANGE OF USE - HOLIDAY ACCOMMODATION, PRESCRIBED TIDAL WORKS & PRELIMINARY APPROVAL FOR OPERATIONAL WORKS FOR DESTRUCTION / REMOVAL OF MARINE PLANTS – WILLIAMS ESPLANADE & CORAL COAST DRIVE PALM COVE – DIVISION 10 Luke Jackson : 8/7/1417 : #1838165 PROPOSAL: HOLIDAY ACCOMMODATION INCLUDING ANCILLARY DAY SPA AND RESTAURANT WITH BAR PRESCRIBED TIDAL WORKS PRELIMINARY APPROVAL FOR OPERATIONAL WORKS FOR DESTRUCTION/REMOVAL OF MARINE PLANTS APPLICANT: PC CAIRNS PROPERTIES PTY LTD C/- CONICS (CAIRNS) PTY LTD PO BOX 1949 CAIRNS QLD 4870 LOCATION: WILLIAMS ESPLANADE AND CORAL COAST DRIVE PALM COVE PROPERTY: LOT 1 ON RP748655 LOT 3 ON RP 747724 EASEMENT C RP 747724 IN LOT 0 ON BUP 70885 PLANNING DISTRICT: CAIRNS BEACHES PLANNING AREA: TOURIST AND RESIDENTIAL PLANNING SCHEME: CAIRNSPLAN 2005 REFERRAL AGENCIES: DEPARTMENT OF NATURAL RESOURCES & WATER

DEPARTMENT OF MAIN ROADS ENVIRONMENTAL PROTECTION AGENCY

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QUEENSLAND TRANSPORT DEPARTMENT OF PRIMARY INDUSTRIES & FISHERIES MARITIME SAFETY NUMBER OF SUBMITTERS: NA STATUTORY ASSESSMENT DEADLINE: 9 DECEMBER 2009 APPLICATION DATE: 16/09/2008 DIVISION: 10 APPENDIX: 1. SUBMITTED PLAN(S) & DOCUMENT(S) 2. CONCURRENCE AGENCY CONDITIONS & REQUIREMENTS LOCALITY PLAN

Subject Site

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RECOMMENDATION: A. That Council issue a Preliminary Approval for Material Change of Use (Code

Assessment) for Holiday Accommodation, Prescribed Tidal Works and a Preliminary Approval for Operational Works (destruction/removal of marine plants) over land described as Lot 1 on RP 748655, Lot 3 RP 747724 and Easement C RP 747724 on Lot 0 BUP 70885, located at Williams Esplanade & Coral Coast Drive Palm Cove, as directed by the Department of Environment and Resource Management (DERM) by correspondence dated 24 June 2009.

B. That Council issue a Preliminary Approval for Material Change of Use (Code

Assessment) for Holiday Accommodation, Prescribed Tidal Works and a Preliminary Approval for Operational Works (destruction/removal of marine plants) over land described as Lot 1 on RP 748655, Lot 3 RP 747724 and Easement C RP 747724 on Lot 0 BUP 70885 located at Williams Esplanade & Coral Coast Drive Palm Cove, subject to the following additional requirements being met:

Amended Plan

1. The road layout and position of building envelopes must be amended to accommodate significant trees on site in accordance with a tree survey plan and to minimize the visual impacts of bulky buildings from surrounding areas. The applicant is to submit a plan detailing the location of all trees with a trunk diameter of more than 300mm within the vicinity of the roads, parking areas and proposed buildings and showing proposed amendments to the development which will accommodate such trees. It must be clearly demonstrated that the development can be screened by existing vegetation from surrounding areas. Where this can not be demonstrated, buildings must be redesigned including reducing height, increasing spacing between individual buildings, increasing spacing between buildings, roadways and vegetation and reducing the bulk of buildings.

2. The building proposed adjacent to Colonel Cummings Drive is to be redesigned so that it complies with the minimum setback and height requirements of the Multi Unit Housing Code. Visual Amenity in Coastal Management Area 3. The subject lots are located within an area designated as having high

coastal landscape values in the Wet Tropical Coastal Regional Coastal Management Plan (WTCRCMP). The applicant is to provide greater detail as to the impact of the proposal upon the aesthetic significance of the site (refer to Policy 2.7.2 of the WTCRCMP). This will require an assessment of the impact of the development on the scenic and cultural values associated with coastal landscapes.

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A report is to be prepared demonstrating that the proposal is of a height, scale, design, landscaping, location and site coverage that maintains the values of and protects areas of landscape significance. The report is to be prepared and certified by a qualified landscape architect or landscape planner that demonstrates that the development is compatible with maintaining the values of the areas of landscape significance.

Revised Earthworks Master Plan 4. Revised earthworks master plans must be prepared by a qualified and

experienced engineer. The plans must show the full extent of earthworks required for the roads and building pads on common plans. This detail must be provided in both plan view and in sections and must show all earthworks required including private roads, building pads access tracks and driveways.

The plans must identify any earthworks proposed in areas of the site

with slopes steeper than 1 in 4 and provide justification on why the footprint is proposed to extend into these steep areas. The plans must also dimension setbacks to gullies and localised very steep sections.

Copies of these plans must be provided to the geotechnical engineer to

enable an assessment of the impact on stability based on the full scope of works proposed.

Geotechnical Report 5. A geotechnical and natural hazard assessment (landslide) report must

be prepared by a qualified and experienced geotechnical engineer. The report shall examine the existing site conditions, including the soil/rock type, depth and properties; and extent of weathering. The report should include an assessment of the risk level of the site in accordance with AGS Guidelines (2007) and provide history of any known geological problems or occurrences on the site or adjoining property. This risk assessment should incorporate, but not be limited to, the following factors:

● slope stability with appropriate loadings applied reflecting the

proposed works; ● erosion stability; ● existing surface water characteristics and proposed treatments for

surface water; and ● location of and concentration of ground water. The geotechnical assessment must be carried out based on the scope

of works proposed for the earthworks shown on the revised engineering plans.

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The geotechnical report is to reference the engineering plans and note

the locations of cut and fill batters in relation to existing steep areas of the site.

Revised Traffic Study 6. The applicant/owner is to undertake a revised traffic study and produce

a traffic management plan to show how the effects of the increased traffic will not detrimentally affect existing operations of the jetty and boat ramp car parking or traffic flow on the northern section of Williams Esplanade.

The traffic study shall include (but not be limited to) the following

information: ● Expected traffic generation based on CairnsPlan and FNQROC

generation rates and comprising average daily morning and afternoon peak hours,

● Expected travel patterns, traffic distribution and vehicular types for both commercial and passenger,

● Analysis of intersection(s), including proposed treatment and method of control,

● Analysis of boat ramp and jetty uses, including proposed treatment and method of control,

● Estimated vehicle storage requirements on site to ensure that no overflow occurs to the existing carpark,

● An assessment of whether provision of channelisation through the car park (both the sealed and currently unsealed sections) is beneficial,

● Assessment of the implications of this development (intersection and traffic) on the concept plans for the closure of Williams esplanade and the redirection of traffic to the west of the Caravan Park. Plans of the concepts will need to be obtained from Council in this regard.

Any adverse implications for existing accesses, carpark users, jetty and

boat ramp use, traffic safety, roadway and intersection capacity and levels of service shall be identified and appropriate recommendations made with regard to any measures necessary to minimise such adverse effects.

The traffic management plan shall demonstrate how the conflict points

between the existing users (boat ramp, jetty and car parking) and the increased traffic load generated by the development will be addressed to ensure that a no-worsening arrangement has been achieved for the existing lawful uses.

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Creek Crossing 7. The applicant/owner is to provide additional details on the options for

the creek crossing near the entrance to the site. The details are to show the full footprint of a culvert option and a bridge option.

The culvert option is to show the evidence to support the statements in

the engineering report that this is the lower impact option. Details shall include site plans and concept cross sections for the crossing. Any wing walls, aprons and upstream and downstream protection must be shown.

An alternative bridge option is also to be shown. Any mid span piers

required are to be identified including access for construction equipment. It is noted that where the footprint can be limited to the piles and headstocks the disturbance of the creek invert can also be limited. In the event that the site constraints including deck spans prohibit a bridge this detail is to be provided to support this finding.

Car parking 8. The applicant/owner is to provide additional details confirming that the

proposed carparking complies with AS/NZS 2890.1 Off Street Parking code and with Queensland Streets.

Details must include aisle widths, gradient of parking bays, distance

from dwellings and manoeuvring areas. Link Road 9. The applicant owner must include the current preliminary design for the

link road between Coral Coast Drive and Colonel Cummings Drive on its development plans to confirm the footprint required for the road link and also confirm that access from this road can be achieved. In this regard the design shall ensure the driveway sight distances and horizontal and vertical geometry at the proposed entry/egress point are in accordance with the relevant standards. Details on these elements are to be provided to Council.

CONCURRENCE / REFERRAL AGENCY CONDITIONS & REQUIREMENTS

Concurrency Agency Concurrence Agency Ref

Date Council Electronic Reference

Department of Environment and

Resource Management

0181972 IPCC01284108 IPCC01284008

24/06/2009 2146692

Department of Employment, Economic

Development & Innovation

NFC/140/000(085) 19/06/2009 2142013

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Queensland Transport CRN 217 17/04/2009 2030515 Department of Natural Resources and Water

ICI006CNS0007 15/12/2008 &27/11/2008

1912723

Refer to Appendix 2: Concurrence/Referral Agency Requirements. (Please note that these conditions / requirements may be superseded by subsequent negotiations with the relevant referral agencies). ADVICE 1. This approval, granted under the provisions of the Integrated Planning Act

1997, shall lapse four (4) years from the day the approval takes effect in accordance with the provisions of Section 3.5.21 of the Integrated Planning Act 1997.

2. This approval does not negate the requirement for compliance with all other

relevant Local Laws and other statutory requirements. 3. Please note that the contributions must be paid at the rates applicable at the

time of payment. Updated calculations must be requested prior to payment. 4. For information relating to the Integrated Planning Act 1997 log on to

www.ipa.qld.gov.au. To access Council’s Development Manual, Local Laws and other applicable Policies log on to www.cairns.qld.gov.au.

EXECUTIVE SUMMARY: An application has been submitted for a Material Change of Use (Code Assessment) for Holiday Accommodation Units, Prescribed Tidal Works and a Preliminary Approval for Operational Works. The site is located at the northern end of Williams Esplanade, Palm Cove and contains the first headland north of the beach as well as a tidal waterway, rainforested gullies and forested hill tops. The site is presently vacant. The land is located in a Tourist and Residential Planning Area. Assessment of the application reveals that the applicant has provided insufficient information to enable Council to provide conditions of approval. Additional information is required in relation to existing vegetation and the ability of the development to accommodate mature vegetation, visual amenity impacts within the Coastal Management Area and engineering issues including traffic, geotechnical issues, access and cut and fill. The proposal was referred to several referral agencies. The Department of Resource Management as a concurrence agency for the application directed Council to issue a preliminary approval. The proposal is therefore recommended for a preliminary approval.

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PLANNING CONSIDERATIONS: Background An application for the Reconfiguration of a Lot (2 into 27 lots) at the site was refused at the previous Council meeting on 25 November 2009. The grounds for refusal are as follows:

1. The proposed development is contrary to the purpose of the Hillslopes Code, particularly the following purposes:

● The ecological values, landscape character and visual quality of the

hillslopes are protected from development so as to retain the scenic backdrop to the City; and

● Development on hillslopes is appropriate, having regard to the

topographic constraints and environmental characteristics of the land; and

2. The proposal is contrary to the desired development outcomes and

performance criteria of the Vegetation Conservation and Waterway Significance Code.

3. The proposal is located on a visually prominent headland and the proposed

development will result in adverse visual amenity impacts upon the scenic values and visual backdrop of the site.

4. The proposal is contrary to the desired development outcomes and

performance criteria of the Reconfiguration of a Lot Code. Site and Surrounds The development is proposed over two lots which are described as Lot 1 RP 748655 and Lot 3 RP 747724. The site is located at the northern end of Palm Cove and is adjacent to Williams Esplanade and Colonel Cummings Drive. The site contains two lots which are vacant and occupy a combined area of 6.7269ha. Access is available to the site from Williams Esplanade, Colonel Cummings Drive and Coral Coast Drive to the west via an access easement (easement C RP747724 contained in Lot 0 BUP 70885). The site contains a tidal creek over the southern portion that contains mangroves. Further north of this, the land rises relatively steeply for a short distance and contains rainforest. The land becomes flatter at the higher portion of the site. On the higher slopes sparse eucalypt vegetation and open woodland can be found. The rise in land height from Williams Esplanade to the highest point on the site is 60m. The northern part of the site contains an elevated ridge with a height of approximately 25-30m that falls sharply on the northern side down to a small beach. An access trail from the car park on the northern end of Williams Esplanade winds through the site to the top of the ridge on the north eastern side of the property.

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Surrounding development to the east and north is Williams Esplanade and the Coral Sea. The Palm Cove Jetty is located to the east of the site and the Palm Cove Caravan Park is to the south of the site. Oceans Edge, a residential subdivision, is located to the west and south of the site. Dwellings and units at Buchans Point are located to the north of the site. Proposal It is proposed to construct a Holiday Accommodation development at the site. The units are configured as follows:

● 76 suites contained within 19 x two storey buildings; ● 24 suites contained within 3 x two storey buildings; ● 7 suites each contained within 7 x single storey buildings; ● A day spa containing 4 treatment rooms.

The units are proposed to be located on the higher flatter section of the site where the vegetation becomes more open. It is also proposed to provide 18 guest suites in the western arm of the site contained within a three storey building including basement level car parking for 19 vehicles. The total number of suites/units is 125 with 107 units having a studio design and containing one bed, 3 units are two bedrooms and 15 units are 3 bedrooms. The proposal also includes as single storey central facilities building containing lobby, restaurant, bar and housekeeping facilities, 51 car parking spaces comprising of 20 staff spaces, 25 guest spaces and 6 spaces allocated to visitor carts, an access roadway and pedestrian/golf buggy tracks throughout the site. The maximum height of the proposal is 11.5m. The units adjacent to Colonel Cummings Drive are 3 storeys with a basement car park while the other buildings are single and two storeys. An internal road network accessed off Williams Esplanade will provide access to most of the units except for the units on the western arm of the site that will obtain access off Coral Coast Drive via an easement. The proposal also entails additional components being prescribed tidal works and a preliminary approval for operational works for destruction/removal of marine plants. CairnsPlan Assessment

CairnsPlan Cairns Beaches Planning District

Code Applicability Compliance

Planning Area Tourist and Residential Requires Additional Information

Land Use Material Change of Use – Holiday Accommodation Requires Additional Information

Hillslopes Complies Overlays

Vegetation Conservation & Waterway Significance Requires Additional Information

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Cultural Heritage r NA Potential or Actual Acid Sulphate Soil Material Complies Bushfire Management Complies Flood Management Complies Height and Impact of Buildings r NA Operational Aspects of the Cairns International Airport r NA

Demolition r NA

Excavation and Filling Code Requires Additional Information

Infrastructure Works Code Complies Landscaping Code Complies Parking & Access Code r NA Reconfiguring a Lot Code r NA

General

Development Near Major Transport Corridors & Facilities r NA

Compliance Issues Tourist and Residential Planning Area The proposed development satisfies the intent of the Tourist and Residential Planning area. In particular the proposal satisfies the following desired development outcomes:

● The development of tourist accommodation in a wide range of accommodation types is facilitated;

● The scale and density of development contributes to a high standard of

amenity; ● The development achieves an attractive built form, creates a pleasant

environment and is appropriate for the tropical climate of Tropical North Queensland and is sympathetic to the location.

The proposal provides a total of 125 tourist suites within a variety of building types ranging from studios to three bedrooms. The proposal will have a density of 220.5 persons over the 6.7ha site which equates to a population density of 32.8 persons per ha. This complies with the maximum density of 400 persons per ha. The low density proposed is in response to the constraints of the land. The density is less than the density of surrounding properties. Despite the low density of the proposal, there are several large building envelopes that are clustered together and there is concern that these envelopes will appear bulky from surrounding areas if they are not properly screened with vegetation or designed to fit in with the constraints of the site. Additional information is therefore required to be submitted to ensure that the buildings have an appropriate scale and density, have an attractive built form which creates a pleasant tropical environment and are sympathetic to the location. Additional information will need to be submitted by the applicant as part of a preliminary approval to ensure the intent of the Planning Area is achieved. Multi Unit Housing and Holiday Accommodation Code The proposal generally satisfies the relevant acceptable measures within the code including height, landscaped area, site cover, variation in design, and the like.

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Notwithstanding this, the applicant has failed to demonstrate that the development has been appropriately designed in consideration of the site constraints. In particular because of the sloping nature of the site and significant vegetation, additional information will need to be submitted which demonstrates that the proposed buildings will have a minimal visual impact from surrounding areas and will blend in with the existing mature vegetation on the site. The proposal does not comply with setbacks to Colonel Cummings Drive where a 6m setback to the street is required and 3m side and rear setbacks. It is noted that a sewer line crosses this site at this point. The applicant will need to provide an amended building design that addresses the setback requirements of CairnsPlan and either sites the building clear of the sewer or relocates it. Hillslopes Code The majority of the site is located outside of the Hillslopes Overlay. However, two small areas are affected by the overlay. The north-western side of the site is located within the Hillslopes Category 2 area. A small area located centrally within the property on the northern side contains a knob that is located in the Hillslopes Category 1 area. The majority of these areas are not proposed to be developed. The units adjacent to Colonel Cummings Drive are affected over a small area by the Hillslopes Overlay. As this area is very small, it is not considered necessary to relocate the building. Appropriate building colours and materials will be required to soften the impact of these units. Vegetation Conservation and Waterway Significance The tidal area at the southern side of the site contains a mangrove forest with a rainforested edge. This area is nominated as being in a Key Conservation Area and has a Waterway of Significance. It is not proposed to develop this area apart from creating the access from Williams Esplanade, over the tidal area and to the proposed units. The proposed access is aligned adjacent to an existing track which is cleared of vegetation. The impacts to the waterway in the area will be minimal. However, because the proposed road does not follow the alignment of the existing track, it is likely that trees will need to be removed. A design which results in minimal disturbance to the existing vegetation will be required including altering the position of the road if necessary. The remainder of the site is nominated as having Low Conservation Values. The proposed units are primarily located in the area containing low vegetation conservation values. Despite this, there are significant trees at the site and a continuous canopy of vegetation that creates an important and aesthetic visual backdrop at the northern end of Palm Cove. To ensure that the impact of the proposal to vegetation and the visual backdrop is minimised, building envelopes, covenants and common property is proposed. It is considered that this will largely be effective in preserving the visual backdrop and integrity of the vegetation at the site, particularly on the lower slopes.

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Some concern is raised with respect to the impact of vegetation loss generated by the road and several envelopes. It may be that the impact is minimal however based on the information provided, this can’t be ascertained. Therefore the applicant is required to provide a detailed tree survey and an indication of the trees to be removed. The applicant must demonstrate that the proposal will be designed to accommodate vegetation where possible. It is considered that this can be satisfactorily resolved with an appropriate condition. Flood Management The tidal creek area within the site is subject to Q100 inundation. Access to the units must cross over the Q100 inundation area and therefore should be designed to be Q100 immune. Two of the guest suites on the southern side may marginally be affected by the Q100 inundation. Conditions will be imposed to ensure that they are relocated or are designed such they are 100 flood immune. Bushfire Management The site is located in an area with medium bushfire risk. A Bushfire Management Plan is to be submitted to Council for approval prior to a Development Permit for Building Works to ensure that matters relating to bushfires are addressed in the proposal. 2031 Regional Plan The site is located within the area designated as “Urban Footprint” in the Regional Plan. The proposal does not need to be referred to the Department of Infrastructure and Planning. Parking The proposal generates a parking demand of 98.25 spaces. The application provides for a total of 90 spaces. The applicant provides the following reasons to justify the non-compliance: The proposal complies with the Performance Criteria. Although the proposal does not meet the Acceptable Measures defined herein, it is recognised that Council has in the past offered dispensations for parking requirements for similar establishments on the grounds that most visitors will not be self-drive, but rather fly in tourists who are likely to access the site via public transport and therefore will not generate additional car parking need. It is also noted that if Council is of the mind that additional car parking is required onsite, these may be provided along the internal roadways etc. The proposal provides 90 spaces and results in a non-compliance of 8.25 spaces. Despite the minor non-compliance with the acceptable measure for the proposal, the parking rate applied is considered satisfactory to meet the needs of the proposal.

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Vegetation Despite requesting further information in relation to site constraints and in particular a tree survey, the applicant has provided a lack of detail regarding the existing vegetation on the site and the ability of proposed buildings to blend in with the vegetation at the site. The visual impact of the proposal from surrounding areas can’t be determined without this information. Visual Amenity There is concern that the proposal will be significantly more visible from surrounding areas than anticipated by the applicant and without the required information, Council is unable to assess this impact. As the development is located on one of the most visually prominent sites in Palm Cove and is in a Coastal Management area, it is necessary to determine this impact and what design solutions/amendments can be made to ensure that the proposal will not adversely impact upon the significant visual backdrop. Additional information therefore needs to be submitted. Earthworks The extent of earthworks, cut and fill batters, and hence vegetation removal, is not accurately shown on the current master planning drawings prepared by the engineering consultant. The extent of batters (cut and fill) from the roads and building platforms are not shown on common plans. Also the earthworks cut and fill shown in the road cross sections have not been shown as an earthworks footprint and finished surface contours in a plan view. Many of these batters are significant and are adjacent to areas of the site that have steep slopes. The current engineering report does not address these key issues. The earthworks required to construct the infrastructure proposed under this planning application will then need to be assessed by a qualified Geotechnical Engineer. The assessment must reference the actual scope of earthworks proposed. Geotechnical Matters With respect to Geotechnical Issues, a new report must be prepared in accordance with the AGS guidelines for the actual scope of earthworks proposed. Traffic The traffic report referenced is for a different site and by engineers not involved in this application. The engineering consultant has drawn conclusions from this report, but are not the authors of the report. Findings of the consultants report with respect to traffic generation are therefore not supported. The report relies on the Department of Main Roads (DMR) Road Planning and Design Manual for traffic generation rates. FNQROC and CairnsPlan rates should be used.

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Furthermore, the findings of the consultant’s report with regard to upgrades required are not supported. The report states that no upgrades are required to the Northern end of Williams Esplanade notwithstanding the conflicts with users of the jetty and boat ramp and the current “low key” environment that exists. The introduction of through traffic into this environment will have an impact and the reports conclusions are refuted. The report ignores the fact that the access is through the jetty carpark. The plans omit the carpark and do not show that the connection is to an unformed section of informal carpark. In this regard the plans are misleading. The report does not address how conflict with carparking will be managed. Access over the Creek The consultants have represented that in accessing the site over the tidal waterway on the site, a culvert has less impact than a bridge. The consultant represents that a culvert system has been selected as there will be less excavation to install a culvert slab than to install bridge footings. They further say that a bridge will require a similar amount of vegetation clearing and deeper excavations for footings. Furthermore, the loading on the natural ground from the culvert slab is less concentrated than that of bridge footings, and is thus better suited to areas of PASS. This is not supported by Council Officers. Almost all bridges are constructed with a headstock sitting on a piled foundation. The piles carry the load and therefore no other loads need to be transferred to the ASS/PASS. The use of a bridge crossing generally eliminates the need to disturb the creek bed if a single span crossing is used as and banks as the piling and headstocks are located on the high banks out of the creek. In the event a multiple span bridge is required there will be some disturbance but this is limited to the mid crossing pier and headstock. The culvert crossing requires the whole footprint to be engineered and results in a concrete slab for the full width and length of the crossing. A bridge has less impact on the creek system. It is therefore recommended that a Preliminary Approval be issued for the application subject to the applicant providing information to address the issues raised above. Referral Agencies The application was required to be referred to six different referral agencies, these being: ● Department of Main Roads (DMR); ● Queensland Transport (QT); ● Department of Natural Resources and Water (DNRW); ● Environmental Protection Agency (EPA); ● Department of Primary Industries and Fisheries (DPIF); ● Maritime Safety

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The DERMs referral agency response directed Council to issue a Preliminary Approval. Public Notification / Submissions The proposed development is Code Assessable in the district assessment table for the Cairns Beaches and did not require public notification. HEADWORKS / CONTRIBUTIONS: The proposed development triggers Developer’s Headwork’s Contributions. Contributions will be calculated when a Development Permit is requested. Luke Jackson Planning Officer Action Officer Simon Clarke Manager Development Assessment

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APPENDIX 1 SUBMITTED PLAN(S) & DOCUMENT(S)

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APPENDIX 2 CONCURRENCE AGENCY CONDITIONS & REQUIREMENTS

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