boroondara planning scheme amendment c239dsewebapps.dse.vic.gov.au/.../$file/boroondara+c239+… ·...

Planning and Environment Act 1987

Panel Report

Boroondara Planning Scheme Amendment C239

21 September 2016

Planning and Environment Act 1987

Panel Report pursuant to section 25 of the Act

Boroondara Planning Scheme Amendment C239

21 September 2016

Cathie McRobert, Chair

Boroondara Planning Scheme Amendment C239 Panel Report 21 September 2016

Contents Page

Executive summary .............................................................................................................. 1

1 Introduction ................................................................................................................ 3

1.1 What is proposed? .................................................................................................. 3 1.2 Submissions ............................................................................................................. 5 1.3 The ‘on the papers’ process .................................................................................... 5 1.4 Planning context ...................................................................................................... 6 1.5 Issues dealt with in this report ................................................................................ 8

2 The issues ................................................................................................................... 9

2.1 The effect of the additional building height on the appearance of the property and the character of the area .................................................................. 9

2.2 Impacts on residential amenity ............................................................................. 10 2.3 Traffic and parking ................................................................................................. 11 2.4 The Concept Plan ................................................................................................... 12 2.5 Panel recommendation ......................................................................................... 14

List of Tables

Table 1 Proponent summary assessment of the proposal .................................................. 6

Table 2 Proponent assessment of the proposal against CDZ1 objectives ........................... 7

List of Figures

Figure 1 The site (module 4 shown in red) (source: Proponent submission) ....................... 4

Figure 2 The proposed addition (source: Proponent submission) ........................................ 4

Figure 3 Section showing the proposed addition (source: Proponent submission) .............................................................................................................. 5

List of Abbreviations

CDZ Comprehensive Development Zone

The Concept Plan The Concept Plan – 800 Toorak Road Comprehensive Development Plan August 2005

The Proponent Coles Group Property Developments Limited


Overview

Amendment Summary

The Amendment Boroondara Planning Scheme Amendment C239

Subject Site 800 Toorak Road, Glen Iris

The Proponent Coles Group Property Developments Limited

Planning Authority Boroondara City Council

Authorisation 14 February 2016

Exhibition 28 April to 30 May 2016

Submissions Two submissions opposed the Amendment. They were from:

Mr and Mrs Mazzacca

Portfolio Law on behalf of Mr and Mrs Mazzacca. This submission was withdrawn. Council advised the Panel that it had attempted to contact Mr and Mrs Mazzacca, without success, to clarify whether they had also withdrawn their submission.

Panel Process

The Panel Cathie McRobert, Chair

Directions Hearing Planning Panels Victoria, 8 August 2016

Directions Hearing appearances:

Boroondara City Council represented by Nick Brennan, Senior Strategic Planner, Boroondara City Council

Coles Group Property Developments Limited represented by Bernard McNamara of BMDA Development Advisory

Submissions considered ‘on the papers’

The objecting submitter did not request to be heard (see Chapter 1.3)

Submissions from Council and the Proponent were considered ‘on the papers’.

Site Inspections Unaccompanied, 9 September 2016

Date of this Report 21 September 2016


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Executive summary Summary

Amendment C239 to the Boroondara Planning Scheme (the Amendment) is required to facilitate the development of a single storey addition of approximately 800 square metres at 800 Toorak Road, Glen Iris to house a conference, meeting and training area with associated support facilities.

The Amendment proposes to amend the Concept Plan – 800 Toorak Road Comprehensive Development Plan August 2005 (the Concept Plan) by increasing the maximum developable height for the module 4 building from 55.30 metres to 61.00 metres.

The site is within the Comprehensive Development Zone Schedule 1 (CDZ1), which requires any buildings and works to be generally in accordance with an endorsed Concept Plan. A planning permit is not required for development if the zone provisions, including consistency with the Concept Plan, are met.

Submissions

Council received two objecting submissions to the Amendment from:

the owners of 807 Toorak Road, Hawthorn East

lawyers on behalf of the owners’ behalf of 807 Toorak Road, Hawthorn East, which was withdrawn (4 July 2016).

Key issues raised in the submissions were:

the increased building height will have a detrimental impact on the existing residential character, amenity and appearance of the neighbourhood

overlooking of adjacent properties

increased traffic outside of business hours

the lack of traffic impact assessment.

Panel conclusions

The Panel agrees with Council and the Proponent that the minor additional height and floor area facilitated by the Amendment will have minimal effect on:

the appearance of the property and the character of the area, given the integration of the proposal with existing built form on the site and the context of buildings of significant scale in the immediate area

the amenity of residential uses, due to the separation of the proposed addition from residential uses, including 807 Toorak Road, Hawthorn East

traffic impacts and congestion given the context of the busy Toorak Road traffic and the shopping centre. A traffic report is not warranted for the limited extent of additional floorspace proposed.

The Panel agrees with Council and the Proponent that the replacement of the existing single sheet Concept Plan with a detailed 24 page Concept Plan could result in the need for planning scheme amendments to address matters of detailed design. The Concept Plan should focus on the approved building envelope, with the subsequent approval of the


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Overall Development Plan (which must be generally consistent with the Concept Plan) to address more detailed issues.

Panel recommendation

Based on the reasons set out in this Report, the Panel recommends Boroondara Planning Scheme Amendment C239 be adopted as exhibited subject to the following:

Update conditions for office use in Schedule 1 to the Comprehensive 1.Development Zone table of uses to refer to the proposed new Comprehensive Development Plan, October 2015 (rather than the Comprehensive Development Plan, August 2005).

Include the following plans in the Concept Plan – 800 Toorak Road Comprehensive 2.Development Plan: the 2005 concept plan updated to show the increased maximum height of

building module 4 the proposed roof plan (ATP‐20004) south elevation (ATP‐40001) west elevation (ATP‐40002) north elevation (ATP‐40003, ATP‐40004 ) east elevation (ATP‐40005) section A (ATP‐50002, ATP‐50003) a notation explaining how the relative levels were determined.


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1 Introduction

1.1 What is proposed?

(i) The Amendment

The Amendment proposes to amend the Concept Plan – 800 Toorak Road Comprehensive Development Plan August 2005 (the Concept Plan), which applies to the CDZ1 and is incorporated in the planning scheme. The revised Concept Plan shows the new meeting area and increases the maximum developable height for the module 4 building from 55.30 metres to 61.00 metres. An exemption to the maximum allowed heights is proposed to accommodate lift overruns and plant.

Whereas the existing Concept Plan consists of one sheet showing the maximum allowable building heights, the replacement Concept Plan comprises 24 sheets showing the specific architectural concept. The CDZ1 and Clause 81.01 will be updated to refer to the revised Concept Plan.

Post‐exhibition changes to the Amendment

After exhibition, Council supported the following change to the Amendment:

The Table of Uses in the CDZ1 be updated to replace the reference to the previous Comprehensive Development Plan (August 2005) with a reference to the proposed new Comprehensive Development Plan (October 2015) in the conditions to Office use.

The Panel endorses this minor consequential change to the Amendment.

Panel recommendation

Update conditions for Office use in Schedule 1 to the Comprehensive Development 1.Zone table of uses, to refer to the proposed new Comprehensive Development Plan, October 2015 (rather than the Comprehensive Development Plan, August 2005).

(ii) The site and area

The Amendment applies to 800 Toorak Road, Glen Iris (outlined in red in Figure 1, with module 4 shaded red). The site, which is approximately 25,300 square metres in area, is bounded by Toorak Road to the north, the Tooronga Village residential and commercial development to the west, St Kevin’s College sports field to the south and residential development to the east. The Monash Freeway is nearby to the south. The major office complex on the site is used as a Coles’ regional headquarters and has a maximum height of 36 metres.


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Figure 1 The site (module 4 shown in red) (source: Proponent submission)

(iii) The proposal

The Amendment is required to facilitate the development of a single storey addition of approximately 800 square metres, to house a conference, meeting and training area with associated support facilities (see Figure 2). The plans provide for dividable conference rooms, audio‐visual support, breakout and foyer areas, outside deck areas, a re‐heat kitchen and toilets.

The proposed new floor level would be built on the disused roof top garden (the entire top area of Module 4) and requires the maximum allowed height to be increased by 5.70 metres. This will make module 4 taller than the surrounding modules, though still not the tallest structure on the site (the central lift tower has a height of 65.40 metres).

Figure 2 The proposed addition (source: Proponent submission)

807 Toorak Road


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Figure 3 Section showing the proposed addition (source: Proponent submission)

1.2 Submissions

Council received two submissions objecting to the Amendment from:

the owners of 807 Toorak Road, Hawthorn East

lawyers on the owners’ behalf, which was withdrawn (letter dated 4 July 2016).

Key issues raised in the submissions were:

1. The increased building height will have a detrimental impact on the existing residential amenity, character and appearance of the neighbourhood.

2. Overlooking of adjacent properties.

3. Increased traffic outside of business hours.

4. The lack of traffic impact assessment.

1.3 The ‘on the papers’ process

At the Directions Hearing, it was noted that:

the objecting submission from lawyers on behalf of the owners of 807 Toorak Road, Hawthorn East had been withdrawn

Council attempts to contact the owners of 807 Toorak Road to clarify whether they maintained their original submission had been unsuccessful

the owners of 807 Toorak Road had not requested to be heard by the Panel.

The Panel agreed to Council’s request for an ‘on the papers’ Panel process, rather than conducting a hearing. The Panel directed that the Council submission address the following matters:

The basis for the maximum allowable height limit that is proposed to be amended.

The effect of the additional building height that would be allowed by the Amendment on the appearance of the property from within the site, adjoining properties and the public realm.

The implications of the development facilitated by the Amendment, including a change in the use of the area to a use that would not require a permit under the Comprehensive Development Zone and the associated incorporated development plan, on:

The amenity of adjoining properties, including overlooking


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Car parking Traffic management

The issues raised in the objecting submissions that requested a change to the Amendment (as is referred to in section 23(1) of the Planning and Environment Act 1987) and any that amount to a request for another amendment.

The Proponent was invited to address these issues if they made a submission.

The Proponent’s written submission to the Panel sought changes to the Concept Plan proposed as part of the Amendment. As Council’s written submission had not addressed this issue, the Panel provided an opportunity for Council to make a written response (see discussion in chapter 2.5).

1.4 Planning context

Council provided a response to the Strategic Assessment Guidelines as part of the Explanatory Report.

(i) Consistency with planning policy

Council and the Proponent highlighted the minor nature of the proposed changes and the limited (if any) specific local planning policy applying to the location and the proposal. It was noted that Clause 21.08 (Activity Centres, Neighbourhood Centres and Commercial Corridors) does not identify the site, which appears to be excluded from the Tooronga Village site.

Both Council and the Proponent submitted that the Amendment accords with the broader objectives and strategies of the State and the Local Planning Policy Frameworks of the Boroondara Planning Scheme. In particular:

the objective of Clause 15.01‐2 Urban Design Principles ‘to create urban environments that are safe, functional and provide good quality environments with a sense of place and cultural identity’

overarching principles to strengthen commercial land use and development in existing locations.

The Proponent summary assessment, provided in Table 1 below, concluded that “the proposal has strong policy support and an absence of policy barriers”.

Table 1 Proponent summary assessment of the proposal

Criteria Proponent Summary Assessment

Location The site is within an existing office complex and in our view is part of the Tooronga Village activity centre.

Alternatively, the site may be regarded as an edge‐of‐centre site and, having regard to the nature of the proposal, it is accommodated in an optimal way.

The small addition to the large office building complex is to be achieved through a design which relates well to the hexagonal forms.


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Criteria Proponent Summary Assessment

Accessibility Being an upper level addition this criterion is only marginally applicable. The facility will be only be accessible from the internal offices.

The access and car parking that might be generated by the development will be very small in the context of the site activity. Coles has leased an additional 1,200 plus car parking building connected to the complex. Car parking requirements for the proposal are met through this large supply.

Urban Design The assessments under this criteria, relate essentially to street‐based proposals. The proposal is an addition to level 6 of the building. It replaces a roof top garden area.

Economic Justification The proposal is a small floor area extension for the purposes of adding meeting and training rooms. It will not have any adverse impacts on local retail centres.

In a minor way the proposal will reinforce the long term occupation of this significant employment location.

(ii) Zones and overlays

The site is within the CDZ1, which requires any buildings and works to be generally in accordance with an endorsed Concept Plan. A planning permit is not required for development if the zone provisions, including consistency with the Concept Plan, are met.

The current Concept Plan was endorsed in August 2005. It is a single map showing the maximum allowable height for each of the 12 building modules. The Amendment proposes an updated concept plan (see discussion in chapter 2.4).

Within the CDZ1 a range of uses, such as an office, are section 1 uses that do not require a planning permit. As Council highlighted, there is no trigger for consideration of hours of use, or traffic within the CDZ1. This limit on the scope of discretion extends to the scope of conditions that can be applied to section 1 uses in the zone.

The Proponent’s written submission included the following assessment of the proposal against the objectives of the CDZ1.

Table 2 Proponent assessment of the proposal against CDZ1 objectives

Objective Proponent Response

To encourage and assist the overall development of the land for an office and ancillary uses.

The amendment will facilitate the operation of an existing business with additional meeting and training rooms. The use of the land for offices will be enhanced without adverse effects on the scale and character of the existing buildings.

To ensure that the combination of uses and the scale and character of any development is compatible with the character, amenity and appearance of the surrounding area, the capacity of the existing and proposed road system to

The amendment will not adversely impact on the streetscape and adjoining residential areas. It is not expected that the proposed amendment will have a discernible impact on the existing road network, nor will compromise the safety or operation of the existing


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Objective Proponent Response

accommodate any increase in traffic, and the capacity of existing essential services including proposed modifications.

transport system.

To ensure that the land is developed in an orderly and comprehensive manner.

The amendment will contribute to the existing role of Tooronga Village as the regionally significant development with the integration of commercial, retail and residential uses.

No overlays apply to the site.

(iii) Panel conclusion

The Panel has made a brief appraisal of the policy context and zone provisions and endorses Council’s view that the Amendment is broadly consistent with State and local planning policy.

1.5 Issues dealt with in this report

The Panel considered all written submissions, as well as written submissions presented in the ‘on the papers’ process. In addressing the issues raised in those submissions, the Panel has been assisted by the information provided as well as its observations from inspections of the site.

This report deals with the issues under the following headings:

The effect of the additional building height on the appearance of the property and the character of the area

Impacts on residential amenity

Traffic and parking

The Concept Plan.

The Panel’s assessment has been confined to the issues raised in the objecting submissions. It has not undertaken a comprehensive evaluation of the proposal.


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2 The issues

2.1 The effect of the additional building height on the appearance of the property and the character of the area

(i) Submissions

The objecting submission expressed concern that the current height controls were put in place to ensure that the development was in keeping with existing residential character, amenity and appearance of the neighbourhood. As that has not changed, it was submitted that the height controls should not be changed.

Council advised that the height limits and associated planning controls were put in place at the time of the original development of the building in the mid‐1980s to ensure that the building remained of a scale that was in keeping with the surrounding primarily residential area. Since that time there has been extensive development on the adjacent land with the construction of the residential towers.

Council submitted that:

the additional 5.7 metres height of a single building module would not compromise the original intent of the height controls

the proposed addition is appropriately integrated into the existing building to ensure that it is not visually intrusive

the residential towers immediately to the west represent a more substantial change to the height profile and character of the area than that proposed within the revised Comprehensive Development Plan

Module 4 is set well away from surrounding residential properties and that the additional height will have little impact on the amenity of surrounding properties.

The Proponent noted:

The proposal would have to its east, the higher existing building modules at RL 58.90 and the services core at RL 65.40. Viewed for the west, the new building will sit mainly within the existing building profile. Views from the Toorak Road public domain are not available due to the existence of the lower, but substantial hexagonal modules at RL 44.5 and RL 55.7, and through the fact that Module 4 is inset about 50 metres from Toorak Road, and about 40 metres from Crescent Road.

With the proposal on the western side of the complex, no views to and from the proposal are available, from the east of the site; the low density residential area of Parkin Street.

Views of the addition will be available from the south and west. This will include views from the residential apartments within Tooronga Village. The closest views are from about 80 metres west. Longer views will be available from Tooronga Road and from the areas well to the south (including from the freeway). The length of these views and absence of any overlooking concerns removes this as a consideration.


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(ii) Discussion and conclusions

The Panel agrees with Council and the Proponent that the proposed additional height and floor area is a minor addition to the major development facilitated by the CDZ1. The land to the south of Toorak Road has a very different character to the residential area to the north.

The Amendment will have little effect on the appearance of the property and the character of the area as the proposed addition it facilitates:

is within a context of buildings of significant scale, both within the Coles site and on adjoining land

will be integrated with the existing built form on the site

will not be prominent in longer views from outside the site.

2.2 Impacts on residential amenity

(i) Submissions

The objecting submission expressed concern that the proposed development will overlook their property at 807 Toorak Road, Hawthorn East.

Council submitted the proposed development would have no unreasonable impact on residential amenity due to the relatively minor scale of the development and the separation of module 4 from residential land or uses. The separation from residential uses is more than 100 metres to residential properties fronting Toorak Road, 90 metres to residential properties in Parkin Street and 80 metres to the residential towers at Tooronga Village. If views from the proposal are possible, they will be distant views.

Although Council noted that ResCode standards do not apply to the proposed development, it highlighted that the proposed development will not result in any increase in overshadowing of private open space, or any unreasonable overlooking of residential properties. ResCode defines unreasonable overlooking as a view into secluded private open space within 9 metres, whereas the proposed development is approximately 100 metres away from the objecting submitter’s property on the opposite side of Toorak Road and about 130 metres from the objector’s residence (a tennis court is located between the house and Toorak Road).

(ii) Discussion and Panel conclusions

The Panel considers the separation of the proposed additional height and floor area from residential uses mean there will be no unacceptable impacts on the amenity of residential uses, including 807 Toorak Road, Hawthorn East. Residential properties will not be adversely affected due to overlooking or overshadowing and the increase in levels of activity will be imperceptible in the context of significant non‐residential uses on the southern side of Toorak Road in this area.


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2.3 Traffic and parking

(i) Submissions

The objecting submissions expressed concern that:

there will be additional traffic out‐of‐hours, as meetings often extend beyond working hours

the development will increase existing traffic congestion in this area and any increase in traffic would have a negative impact on residential amenity

a traffic report or assessment has not been provided.

Council highlighted that the development increases the floor space of the building by approximately 2% and the current car parking provision is well in excess of that required by the CDZ1 for development on the site, including with the proposed additional 800 square metres of floor area. The CDZ1 requires provision of at least 2.9 car parking spaces for each 100 square metres of leasable floor space. At least 1,264 car parking spaces must be provided for the building total leasable floor area of approximately 43,000 square metres, whereas more than 2,400 car parking spaces are provided.

Council and the Proponent submitted that the proposal will have a negligible impact on traffic generation, particularly after hours. A significant increase in traffic generation is not anticipated, as the proposed development will be used as a meeting space for existing staff, although it can be assumed that the improved meeting facilities could accommodate off‐site guests.

Council and the Proponent did not consider that the proposal would result in an increase of traffic that would warrant the preparation of a traffic report. It was noted that the traffic considerations of the rear car park and the changes to the Priority Development Zone land had been recently assessed in the GTA report (Amendment C188). Some of the GTA report findings included:

Toorak Road carries about 30,000 vehicles per day

Crescent Road, which operates as collector to the Coles offices car park, the Tooronga Village apartments, and the shopping centre, carries about 5,000 vehicles per day

The operation of the intersections1 with the development of the multi‐deck car park, and the potential for additional office development on the site was modelled.

The Proponent submitted, as the current proposal involves no additional car spaces, it is unlikely to change any of the traffic engineer’s findings.

(ii) Discussion

The Panel does not consider the objectors’ concerns about negative impact on residential amenity from additional traffic out‐of‐hours and increased existing traffic congestion have been substantiated.

1 Three sets of traffic signals operate within about 220 metres: the intersection of Toorak and Crescent

Roads, Tooronga Road/Toorak Road (west) and Toorak Road/ Coles office entry (east).


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The Panel accepts submissions from Council and the Proponent that, even if car parking generated by the proposal was assessed independently from the existing office use, the 232 car spaces generated by the additional 800 square metres of floor space, represents less than 1% of the car parking provided. While there is not a direct relationship to traffic generation as the turnover of vehicles varies between uses, the Panel agrees with submissions from the Proponent that that the additional traffic generated by the proposal would not be discernible in the context of the busy Toorak Road traffic and intensive development on the southern side of Toorak road, which includes a large office use and shopping centre2.

(iii) Panel conclusions

In the context of the busy Toorak Road traffic and the shopping centre, the additional traffic generated by the proposal would not have a discernible impact on existing congestion and the amenity of nearby residential uses.

A traffic report is not warranted for the limited extent of additional floorspace proposed.

2.4 The Concept Plan

(i) Submissions

The Proponent’s submission noted that Council support for the Amendment came with the requirement to replace the existing single sheet Concept Plan with a 24 page Concept Plan.

The Proponent submitted that the replacement Concept Plan specified in Council’s recommendation is excessive. While there is no disagreement between Council and the Proponent over the location, height and scale of the proposed addition, the Proponent argued that the Concept Plan set be limited the hexagonal modules plan, plus diagrams of floor plans and sections, submitting:

The new set includes the extraneous plans and plans at a different level of resolution. The fundamental approach within CDZ1 is that building scale is managed through an “envelope” approach. Council in 2016 is seeking a level of resolution within the planning scheme that includes locational diagrams, photomontages, shadow diagrams and materials.

The approval of development within the CDZ1 requires the approval of an overall development plan, consistent with the Concept Plan. That means that Council will need to approve the final form of the building, notwithstanding that there is no specific permit requirement. It is submitted that a level of precision can be built into the new Concept Plan without pre‐committing to the design at this early time. This may be achieved by confining the Concept Plan to a set consisting of the floor plans and sections, all of which include RLs. This is consistent with, but advanced from, the current document.

The Proponent submitted that the Concept Plan should consist of:

2 The shopping centre is accessed via Crescent Road/Toorak Road and Tooronga Road. The shopping centre

operates until 9.00pm, with the supermarket operating until midnight.


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800 Toorak Road Building Modules shown on the Concept Plan (the updated Concept Plan from 2005)

Plans prepared by The Buchan Group: Project No. Coles Store Support Centre Meeting Room Project 2015‐2106: ATP‐2001, Existing Level 6 Plan, ATP‐2002, Existing Roof Plan, ATP‐2003, Proposed Level 6 Floor Plan, ATP‐2004 Proposed Roof Plan, ATP‐50002 Section A, ATP‐50003 Section A3.

As Council’s written submission had not addressed this issue, the Panel provided an opportunity for Council to make a written response. The Council response4 noted that:

the endorsed Concept Plan will become an incorporated document and changes to it will require a planning scheme amendment

the CDZ1 requires approval of an Overall Development Plan5 that must be generally in accordance with the Concept Plan and is subject to public exhibition at Council for a minimum of 14 days.

Council considers the incorporated Concept Plan must show:

1. Maximum heights for all of the modules that make up the building.

2. Elevations or sections of the building showing the relative heights of the building.

To avoid a situation where planning scheme amendments are required for relatively minor changes, Council did not considered it necessary for the Concept Plan to show the internal floor arrangements or the schedule of materials, as these matters would more appropriately form part of the Overall Development Plan. Council submitted that the Concept Plan should comprise:

The recreation of the 2005 concept plan showing the maximum height of each of the building modules.

The proposed roof plan ‐ ATP‐20004.

South elevation ‐ ATP‐40001.

West elevation ‐ ATP‐40002.

North elevation ‐ ATP‐40003.

North elevation ‐ ATP‐40004.

East elevation ‐ ATP‐40005.

Section A ‐ ATP‐50002.

Section A ‐ ATP‐50003.

Council also suggested that a notation on the plans that explains how the relative levels were determined would assist in the endorsement of the Overall Development Plan.

3 These plans were included as Appendix 2 of the Proponent’s submission. 4 Dated 29 August 2016. 5 The Overall Development Plan must address heights, land uses, car parking location and layout, floor areas

and landscaping


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(ii) Discussion and Panel conclusions

The Panel agrees with the consensus view that:

excessive detail on the Concept Plan would be likely to necessitate planning scheme amendments for minor changes and should be avoided

the Concept Plan should focus on the approved building envelope.

While the Proponent did not include elevations within the suggested scope of the Concept Plan, the Panel considers that sections and elevations would assist in interpreting the approved building envelope.

2.5 Panel recommendation

Include the following plans in the Concept Plan – 800 Toorak Road Comprehensive 2.Development Plan:

the 2005 concept plan updated to show the increased maximum height of building module 4

the proposed roof plan (ATP‐20004)

south elevation (ATP‐40001)

west elevation (ATP‐40002)

north elevation (ATP‐40003, ATP‐40004)

east elevation (ATP‐40005)

section A (ATP‐50002, ATP‐50003)

a notation explaining how the relative levels were determined.

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