Mod 4 - Extend Trial

I am vehemently opposed to allowing the unfettered growth of festivals in Byron shire, for the million reasons already well documented by the majority of residents of the Shire. The non-compliance issues are scandalous and the Council should prevent further licences based on the operator's flagrant disregard for the guidelines.

Created Subject
Date
19/11/2010 Online Submission from Gillian Rich (object)
C1
concept website submission
ref no 09_0028 Re: proposal cultural event site @Tweed valley way and Jones road, Yelgun.
There are many reasons why this proposal should not be approved. It's operation would have a huge affect on the area in which I live, impacting negatively on our everyday lives and our peaceful enjoyment of our surroundings.
A report from council planners states that the Yelgun proposal exceeds the limits set out in the Events on Public and Private Lands Policy and it's scale is well beyond anything previously mooted by the applicants, or any other music festival applicant. This proposed development would be destructive of the existing local character, particularly that of the North-eastern part of the shire. This area of our shire is where family life has been able to flourish, protected somewhat from outside forces such as tourism. This has allowed a true community to develop with everyday events such as schooling and work, with their particular rhythms, taking precedence over the party culture, that comes with tourism and those attending festivals.

I object to the North Byron Parklands extension because of the increasing potential for a catastrophe on the site.
Cyclone Debbie devastated the Northern Rivers area and North Byron Parklands do not have a plan to cope with a similar situation during an event.
Imagine the chaos of 35,000 people suddenly homeless/tentless with all accomodation booked out, no access to Lismore, Murwillumbah, Tweed hospitals and all services stretched to breaking point dealing with permanent residents.
Are they going to stand 35,000 sopping wet patrons on a hill for a few days without shelter, food, water and toilets.
NBP suggest that they would have sufficient warning to avoid such a catastrophe but with all the warning in the world the Northern Rivers area was taken by surprise with the unexpected deluge.
It would be a self made humanitarian disaster.

> 1. An extension from the state government is not required.
> Parklands can apply to Byron Shire Council for an extension. In fact, the current approval states that Parklands MUST apply to Byron Shire Council toget approval for any festivals after 31 Dec 2017. Why should this be disregarded or overlooked for this application?
>
> 2. The five-year trial is not finished. The trial still has nine months to go. Asking for a lengthy extension at this point is unwarranted and arguably negates any reasonable report based on a full 5 year trial.

> 3. Numerous breaches of the current consent conditions have occurred.These breaches have been documented in the minutes of Parklands’RegulatoryWorking Group, in Parklands’ own performance reports, by resident groups
> (who have done their own monitoring), and the Department of Planning.
Parklands has had ongoing problems with traffic, off-site impacts on residents’ amenity, and more. Noise has been an ongoing issue. Noise breaches were common early on, but after an increase in the noise limits was allowed (making compliance much easier) breaches still occurred.
> Also, the NSW Police recently submitted a report on Splendour 2016 to the DOP, raising concerns about on-site safety, emergency evacuation, and more. Why is this report being ignored? Surely it leaves the department open to litigation in the event of a catastrophic emergency, when one of its own departments clearly has severe and unanswered reservations?
> Allowing a lengthy extension in the face of so many problems cannotbe justified. The proposed extension would reward Parklands for a job NOT well done. One has to question motive and agenda!

> 4. Parklands does not need more monitoring time.
> Parklands says an additional 20 months will give them time to monitor theirperformance further. They have had five years to monitor their performance,and the DOP has had five years to assess their performance. That’splentyof time. They do not need an additional 20 months to see how they are doing. Clearly in the time they have operated resident concerns have been peripheral and of nuisance value only.
>
> 5. Parklands’ claims of â€oesocial and economic benefits” areexaggerated.
> Social impacts have been increasingly negative on nearby residents, and while some local businesses may benefit, not all do. Many businesses thatcater to local residents actually lose money during festivals. Also, any benefits should be weighed against the costs to the community in terms of loss of amenity, disturbances, security and safety issues, etc Why should this little hamlet be so impacted by having a troupe of people, with so little apparent regard for the bush, beach vegetation, the well being of residents and public safety?

I would ask the powers that be to refuse to extend this proposal to waive the full 5 year trial, but further to accord to council the right, as our chosen representatives to make decisions regarding the future of this/these events.
[REDACTED]

It is inconceivable that Splendour in the Grass and Falls are trying for an extension. From the Nth, Sth and West communities are being impacted on in so many ways. Neither Splendour or Falls have met there conditions of consent in noise thousands of complaints but many not registered for reasons that Promoters can inform you of e.g. not enough phone lines, or cant get through, , traffic youth walking down a 4 lane highway as cant get home by Festival transport, that is stuck either on site or off, or not enough,.. camping so close together that one spark and it could be horrific pictures supplied to D.O.P, sanitation not enough toilet so patrons have to go some outside tents.
Not to mention placing residents at risk from telecommunications failure. When Festivals are on many people have very slow or no telecommunications (mobile and computer) even though towers surrounding the site are switched to Festival mode, and extra C.O.Ws are bought in, that only covers punters and on site departments.. Thousands of (Communities) people are affected. It is a duty of care of the state government, council, and festival organizers, to make sure that communities are not putting lives at risk when they cannot ring for an ambulance and get through to the emergency departments. e.g. Police, S.E.S, etc.
This area has just been impacted by the worst floods on record but the N.B.P. site used to be our water catchment. Again as in many years and events before (pictures shown at first PAC and no notice taken) in different rain cell events it's filled up with water becoming an inland lake/sea. There is no way possible that this site could have been evacuated, placing lives at risk.
1. The speed of this event could have left thousands of people on site having to swim for their lives in over 2 meters of extremely fast flowing white water, with barb wire fences in their way to safety, and a long way from shore. People have died in this situation.
2.There is definitely no way they could have gotten cars off the site, or the camping ground emptied in time to stop polluting the whole area. Rivers that feed into the sea would be polluted with high concentrates of petrol, grease and all other contaminates that come from festival punters e.g. drugs, and all manner of ingredients from punters..
3.The case that was bought before the courts only last year to get a ruling in their favor (N.B.P) for a permanent Festival, did not come to pass.
4.Increases in numbers would and could be horrific for communities and on site punters e.g. Lorne ...
5.There is a site not 10 minutes down the road that has grounds that are council controlled and seem to have the flood situation in hand as they did not turn to mud in or after this horrific event of so much rain. Its where they hold the Blues.... this Festival Group. could be moved to there permanently.
6.North Byron Parklands is just a terrible site, right next to the only nature reserve, that runs from the ocean to the Caldera. This reserve has people defecating in it. It is a disgusting situation.
7.In a flood of 20 years up to 100 years depending on where the cell hits, the water can cover the site and also the pit toilets, thus all the waste goes into the water over the reserve and also roads that run around site and that then goes into rivers and ocean. Polluting water that farmers use for months... plus water ways and the Capricornia Canal which had a very distinctive smell to it.
Saving the biggest to last PLEASE READ THE POLICE REPORT says it all ......
8.There is so much more its terrifying. So armed with all this information the two Promotion Groups and the site owners should not be given an extension nor an increase in numbers. NO MORE ....
I am copying this to make sure that it is definitely going through the process ............thank you.......

NSW Gov should reject the application by North Byron Parklands on the following grounds:
1. A decision by the Department of Planning and Environment is unwarranted as this would directly contravene PACs own determination that "Outdoor events following the trial period will require a further approval from the Council under Part 4 of the EP&A Act."

2. A decision by the Department of Planning and Environment is unnecessary as the trial period has not finished and North Byron Parklands has still one festival (Splendour in the Grass) scheduled for which they have the chance to demonstrate that known negative impacts on the environment and amenity for the neighbourhood can be kept at a minimum.

3. The application in the current form is unfounded, namely there are no good reasons for granting an extension of the trial period by 20 months. Numerous breaches of the current consent conditions have occurred, and it is unreasonable for Parklands to argue that they would need such a long time to lift their game, i.e operate within and fully adhere to the consent conditions.
The local council must not be sidelined anymore, if Parklands wishes to continue after the trial period has expired.

There are clear alternatives available to Billinudgel Property Pty Ltd trading as North Byron Parklands that make the Modification unnecessary and an inappropriate alternative.

When Parklands accepted the ruling of the PAC (Planning Assessment Commission), they knowingly were aware that when the Trial Process was over the authority for changes lay with the local Councils. The PAC STATED clearly that, "outdoor events following the trial period will require approval from the Council under part 4 of the EP&A Act".

PL's request is a request to override and sidestep a condition they knowingly knew as one of their conditions. Quite simply, this request should not even be considered by the minister. It is now in the domain of the local Councils by definition of the PAC conditions.

I also wish to raise the concern of the Tweed Byron LAC (police) which has thrown serious concerns for safety at the PL site. Also as a resident I wish to express my concerns with issues of grave concern to local residents in respect to illegal camping (including camping in state forest with all the consequences of that), antisocial behaviour and traffic problems as a result of an inadequate infrastructure to accommodate the numbers being requested.

It is time PL became accountable to the local community, as is the other festival site in the shire, Bluesfest, and the written conditions of the PAC to which PL should adhere.

I believe that the events held at The North Byron Parklands are important to the economy of not only our immediate area, but also for the entire state of NSW. Many people depend on the money earned from working on these events for their families livelihoods throughout the year. We are on the map not only because of the beautiful natural wonderland we live in, but also because of the International Artists tripping over each other to be involved in the arts focussed events like Splendour & Falls that take place annually in our area.

Parklands do not need to apply to the State Government as the current approval states that they must apply to Byron Shire Council for any Festival approvals after 31st December 2017.

The 5 year trial has not yet finished and there have been numerous and documented breaches of the current consent conditions. ie. numerous noise level breaches. I reside 5 kms from Festival site and there have been times where I have had to close all windows at night to counter act the noise. Also all day when outside you can hear the music.

I, like many other residents try to leave the Shire during the Parklands Festivals.

The so called "social and economic benefits" claimed by Parklands are difficult to understand when some business that I frequent tell me that they actually lose money during Festivals.

Antisocial behavior and littering by Festival goers in our neighbourhood is very obvious to me and other residents.

Parklands have had almost 5years to monitor their performance and that is plenty of time.

Because of the above, I strongly object to any extension being granted.

John Sparke

MP09_0028 MOD 4 - Request for extension of trial period (Concept Plan and Project Approval)

South Golden Beach Community Association Inc. objects to the 20-month extension proposed by North Byron Parklands.

We object firstly because Condition C1 of the existing Concept Plan approval calls for Byron Shire Council to give further approvals under Part 4 of the planning regulations after the end of this year. Our members believe that local control is essential to mitigate the impacts of this development that our community has experienced since the five-year trial began.

We also object because the Land & Environment Court recently ruled, with reference to 31 December 2017, that `Whilst the project may continue after this date, the approved concept plan will cease to operate on that date, and the project will need to be approved under Part 4 of the EPA Act if it is to continue. As such, the concept of continuing in perpetuity does not form part of the approved concept plan...' (Billinudgel Property Pty Ltd v Minister for Planning [2016] NSWLEC 139). This ruling clearly states that the current Concept Plan approval has a life of only five years and rejects Parklands' attempt to obtain permanent approval by changing the conditions of consent. That ruling is also pertinent to this extension proposal: The concept plan expires on 31 Dec 2017.

We are also mindful of the many impacts on our community that this development is making. We experience regular problems with traffic, noise, illegal camping on our streets, telecommunications problems, and frequent displays of anti-social behaviour by festival goers, such as uninvited campers helping themselves to residents' water supplies and using residents' properties as toilets. As the festivals have grown in size, these problems have grown in proportion, leaving residents frustrated and often worried for their safety when tens of thousands of people descend on this ordinarily quiet and peaceful area. It's clear that word has gone out that South Golden Beach is so close to Parklands that ticket-holders can avoid the traffic jams, crowds, and expense of staying at Parklands by camping for free on our streets and catching the bus to the festivals. We desperately need our council to be in charge of these festivals so that our amenity and safety will become a priority. Neither is a priority as long as the Department of Planning is in charge.

We were unnerved by the report that the NSW Police recently submitted to the Department of Planning about Splendour 2016, which raised concerns about on-site safety, emergency evacuation, and more. We see now that besides being concerned about our own safety and security, we have good reason to worry about the safety and security of the attendees--many of whom are local youth. The horrific crowd crush at Falls in Lorne just a few months ago was a wake-up call. Festival promoters have assured the public that such a thing could not happen at Parklands, but the police report suggests otherwise. In the face of such issues, the viability of Parklands as a festival site is seriously called into question. Under the circumstances, an extension should not be allowed. If Parklands is going to continue operations, they should at least be working with Byron and Tweed Councils to significantly reduce the impacts and meet the expectations of local residents.

We also point out that it is not the job of the government to provide Parklands with certainty for their business operations, which is what this proposal is asking for. Parklands says that they are making plans for future festivals and must have the certainty of this venue to continue operations. We note that they have been aware of the expiration date of their trial approval all along. They should have planned accordingly and should not now be claiming that they "need" this extension to be successful. The owners of Splendour operated that festival at Woodford in 2011 and 2012 while they were waiting for their Part 3A proposal to be determined and were quite successful. Holding festivals at Parklands is not critical to their business success. The festival promoters should either find another venue or put in a DA with Byron Council.

Our council has raised issues with the handling of sewage and water on the site (Byron Shire Council's comments to the Department of Planning, 11 Jan 2017), and these concern us as well. Despite Parklands' claims, water and sewage issues are not resolved. Until they are, neither an extension nor the permanent approval NBP wants can be supported.

yours sincerely
Kathy Norley (president)
Denise Nessel (vice president)
Angela Dunlop (secretary)
SGBCA

MP09_0028 MOD 4 - Request for extension of trial period (Concept Plan and Project Approval)

I object to the approval of a 20 month extension of the trial period for events at North Byron Parklands for the following reasons:
North Byron Parklands has a current trial approval. Throughout the past 4 years of this trial the festival organisers have consistently breached approval conditions. they should not be granted an extension to this trial as they have not proven that they are able to comply with consent conditions. They cannot be trusted to do the right thing. This festival site is in the middle of a significant wildlife corridor and as such has a detrimental effect on the surrounding wildlife. NSW Police have stated that the thousands of attendees could not be evacuated safely in the event of a flooding or fire disaster. These festivals impact negatively on the amenity of the surrounding neighbourhoods and villages due to illegal camping and other antisocial behaviour. Until the organisers can demonstrate that they can run a festival in compliance with the DOP consent conditions they should not be rewarded with an extension of their current TRIAL approval !!

Yours sincerely
Igor Blumenthal

MP09_0028 MOD 4 - Request for extension of trial period (Concept Plan and Project Approval)

I object to the approval of a 20 month extension of the trial period for events at North Byron Parklands for the following reasons:

1. The DoP has stated in the current trial approval that Parklands can continue holding festivals after December 2017 by submitting development applications to Byron Shire Council. That's what the current approval calls for, and that's what should happen. At the end of the five-year trial, the local council, rather than the state government, should be deciding what is allowed at Parklands.
2. Parklands has not made appropriate provisions for water and sewage on their site, as their current approval requires. In January, Byron Council called attention to Parklands' need to make proper provisions for sewage and water on the site. A DoP consent condition requires Parklands to construct an on-site sewage management system. This has still not been complied with. Trucking in water and putting in a few composting toilets is not enough. An extension should not be granted when they have not demonstrated that they can adhere to the current conditions of consent.
3. The NSW Police recently issued a disturbing report about security and safety at Parklands during Splendour 2016. They noted issues with emergency evacuation, particularly in the event of flood or fire events, safety of movement on site at night, extensive use of drugs and alcohol, insufficient passageways for emergency vehicles, severe traffic and pedestrian issues (e.g., ticket-holders walking on local roads in the middle of the night because of on-site traffic jams), and many other issues. I note that the camping and parking areas of the Parklands site were totally flooded during the recent flood event in Byron Shire on 31 March 2017. This would have been disastrous if this had have occurred during a festival event especially in the middle of the night.
4. The police also said that at Splendour 2016, they did not have enough staff to cover the festival and also provide police services to the community. All of this will only get worse because the next round of festivals will be even larger than the ones held in 2016. An extension of the current approval should not be allowed in the face of such problems.
5. Before, during and after festivals the amenity of the local community is negatively impacted due to the anti-social behaviour of festival goers who camp illegally on private property, dominate the limited public spaces in the area, leave trash, use people's water without permission, light fires, and in other ways disturb and frustrate residents who expect peace and quiet in their homes.

Yours sincerely
Angela Dunlop

The current approval states that Parklands MUST apply to Byron Shire Council to get approval for any festivals after 31 Dec 2017, so it seems redundant, and a waste of time and resources of the department to persue an extention at state level when this has already been stipulated in the original development approval.

The five-year trial is not finished. The trial still has nine months to go. Asking for a lengthy extension at this point is unwarranted. Parklands says an additional 20 months will give them time to monitor their performance further. They have had five years to monitor their performance, and the DOP has had five years to assess their performance. That's plenty of time. They do not need an additional 20 months to see how they are doing.

Numerous breaches of the current consent conditions have occurred.
These breaches have been documented in the minutes of Parklands' Regulatory Working Group, in Parklands' own performance reports, by resident groups (who have done their own monitoring), and the Department of Planning.
Parklands has had ongoing problems with traffic, off-site impacts on residents' amenity, and more. Noise has been an ongoing issue. Noise breaches were common early on, but after an increase in the noise limits was allowed (making compliance much easier) breaches still occurred.

The NSW Police recently submitted a report on Splendour 2016 to the DOP, raising concerns about on-site safety, emergency evacuation, and more. These should be taken very seriously as not only are they not prepared to deal with the huge numbers at NBP, their service to the local community suffers as they are tied up with the overflow from the site into surrounding towns.

I urge you to maintain the original agreement that this matter should be handled by the Byron Shire Council at the end of the trial period, or rule to not extend based on the fact they have had ample time to operate their `trial' events (and failed to meet requirements) and a lengthy extension would be unfair to the local community who deserve to be heard on the matter of a permanent approval.

I wish to object to this application. 5 years is well long enough for North Byron Parklands to complete their trials. If they wish to extend they can apply to Byron Shire council, as per the original approval.

I do not think they have met the criteria, they have 8 months to do so, then they should be held accountable and face the scrutiny we were told they would for permanent approval at that time.

The local community has suffered over 4 years of disruption to our quiet way of life already.

Numerous breaches of the current consent conditions have occurred.
These breaches have been documented in the minutes of Parklands' Regulatory Working Group, in Parklands' own performance reports, by resident groups (who have done their own monitoring), and the Department of Planning.
Parklands has had ongoing problems with traffic, off-site impacts on residents' amenity, and more. Noise has been an ongoing issue. Noise breaches were common early on, but after an increase in the noise limits was allowed (making compliance much easier) breaches still occurred. Also, the NSW Police recently submitted a report on Splendour 2016 to the DOP,
raising concerns about on-site safety, emergency evacuation, and more.
Allowing a lengthy extension in the face of so many problems cannot be justified. The proposed extension would reward Parklands for a job NOT well done.

Parklands' claims of "social and economic benefits" are exaggerated.
Social impacts have been increasingly negative on nearby residents, and while some local businesses may benefit, not all do. Many businesses that cater to local residents actually lose money during festivals. Also, any benefits should be weighed against the costs to the community in terms of loss of amenity, disturbances, security and safety issues, etc.

In regards to the above application for extension of trial for permanent approval by North Byron Parklands:
I oppose the proposed application for the following reasons:
The trial was approved for 5 years ending in 2017.
5 years was agreed and is adequate time to have tested the site and if the proponents can carry out the festivals within compliance of the trial conditions.
There have been a number of breaches over the last 4 years which would indicate that they cannot perform to conditions of consent for the five year trial as it stands.
Noise has been and will continue to be an issue for many neighbours (scattered through out the north of the shire) during the festival times.
It was apparent that the operators were not able to meet the noise allowances when they asked for a modification to their trial consent conditions in 2015 which were approved against community wishes and to facilitate the sale of 51% of the two operating festivals on the site to an oversees consortium.
There were breaches to these modifications in the subsequent Splendour in the Grass festival in 2016 which is proof that the festivals cannot operate compliantly in its current location of North Byron Parklands in Yelgun.
I ask that you refer to the latest police report stating their fears of safety for festival patrons on the site.
Data has been collected over the trial by parklands and the community and this should be sufficient for Byron Shire and Tweed Council's to make a decision under legislation covering Part 4 of the planning act.
This should not be considered as a state significant proposal as there is no financial proof of that being the case.
This development should be under local council control and assessment from the end of the trial period.

Apart from noise, rubbish, inconvenience, lack of infrastructure etc., I think this venue is also totally unsuitable due to its flood proneness. After the recent floods water was still everywhere, even after it had come down one meter off its peak. Where would you evacuate ten thousands of people?

I write on behalf of Northern Rivers Guardians,Inc, a regional group with more than 600 members that encourages sustainable development and opposes developments which we deem as inappropriate. Normally NRG members do not oppose recreational facilities. We find the extended use of the site at North Byron for large scale festivals to be objectionable on the following grounds:
1. The current approval was for a for a 5-year trial which expires in December 2017, Byron Council takes over from the state as the consent authority. For the first time in five years, the local community will have a say in assessing, monitoring, and evaluating the festival development. We want local government to be in charge because this development heavily impacts local residents and the local ecology. We oppose the extension.
2. We want to see an expert evaluation of the 5 years already trialled. The festivals need to be brought under stricter controls, as emergency services have pointed out. WE are told that the NSW state government has been very lax in its oversight, having prepared only one compliance report since 2012. Numerous breaches of consent conditions have occurred, but the state has responded with only "recommendations" and two mild fines for breaches of noise limits. Byron Council, in consultation with Tweed Council, could be in a better position to ensure compliance and safety.
3. The festivals are disturbing to residents. Noise, traffic, illegal camping on residential streets, and anti-social behaviour from "partying" festival-goers are all taking their toll on residential amenity. Many local businesses lose revenue when festivals are going on because locals stay away. We do not want another 20 months of business and domestic disruption.

4. Parklands asks for the extension so that it will have time to prepare a proposal to become a State Significant Development with permanent approval to hold more and larger festivals on site in future. We don't want them to be granted permanent approval, and we don't want another 20 months of festivals while they prepare their proposal already festivals attract more than 35,000 people and Parklands intends to apply for even greater numbers .
5. Parklands is claiming that they will be in serious trouble because they will not have the certainty they need to run their festival business. Yet when their current approval was being assessed (and they did not yet have approval to hold festivals at Parklands), they took Splendour to Woodford and had two successful years there (2011, 2012). They do not need this extension to stay in business. Furthermore, is should not the duty of government to protect large businesses, but to protect existing land users.
6. Parklands has known for five years that their approval would expire at the end of this year, yet they did not plan accordingly and have not approached Council as the soon-to-be consent authority. Instead of asking for an extension, festival organisers should manage their affairs better. It seems like extortion to come crying to the government now after 5 years trial.
7. No adequate study has been publicly released on the impacts of all the noise and traffic on residents and wildlife in the area. We have seen photos of the debris left behind by hedonistic festival patrons who don't seem to give a rat's entrails about anyone but themselves. Maybe the festivals should go somewhere else where the residents have a similar disregard for the welfare of our world: perhaps Rome during the time of Emporer Nero?
Please do the right things and allow the local people to have the final say on this development.
Faithfully,
Scott Sledge
NRG President
PO Box 309 Murwillumbah NSW
0417 1947 88 25th April 2017

RE; Exhibition of Modification Request
Cultural Events Site, North Byron Parklands
APPLICATION No. MP 09_0028 MOD 4

Date, 27/03/2017

I [REDACTED]


wish to register my objection to Parklands (PL) being given this modification.
I am objecting because I feel that for PL to be given this modification would be to reward `bad behaviour'.
Numerous breaches of the current consent conditions have occurred.
These breaches have been documented in the minutes of Parklands' Regulatory Working Group, in Parklands' own performance reports, by resident groups (who have done their own monitoring), and very occasionally by the Department of Planning.
Parklands has had ongoing problems with traffic, off-site impacts on residents' amenity, and more. Noise has been an ongoing issue. Noise breaches were common early on, but after an increase in the noise limits was allowed (making compliance much easier) breaches still occurred. Also, the NSW Police recently submitted a report on Splendour 2016 to the DOP, raising concerns about on-site safety, emergency evacuation, and more.
Allowing a lengthy extension in the face of so many problems cannot be justified. The proposed extension would reward Parklands for a job NOT well done.
The time has come when the conditions of the PAC (Planning Assessment Commission) are adhered to. That is, as set out in the agreement accepted by PL, "outdoor events following the trial period will require approval from the Council under part 4 of the EP&A Act".
The time has come for PL to become accountable to the local community and to do what is expected from them and to work with the local community that they are part of. They have had the benefit of state government in getting established and to help them find their feet. Five years was the time given and now it's time to begin working in a partnership.
I fervently hope that you will stand by the PAC conditions of the original conditions of PL approval and deny this modification.
Yours with respect,


[REDACTED]