A building integrating living areas with a garage or carport is properly characterised as a 'self-contained residence' and hence a 'dwelling' for the purposes of the Development Regulations 2008 (SA), so that townhouses with integrated garages can constitute 'row dwellings' (Category 1). The Public Notification table in a development plan operates to render Category 1 developments as Category 2 where aggravating features are present, but does not operate to reduce Category 3 developments to Category 2. The Environment Court's jurisdiction on a s 86(1)(f)(ii) review is confined to the categorisation decision and does not extend to challenges to the validity of the ensuing development plan consent on any ground unrelated to categorisation.
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