Hi Andrea
Based on the information provided I would press them on meeting the criteria of the legislation, we have had similar requests and declined to grant exemptions.
The Salvation Army is a religious body, they meet that criterion. They need to use the property for the purposes in their constitution and these properties most likely do not have a permitted use under your LEP to be a place of public worship.
The main issue and show stopper for me is that the Act says, ‘land that belongs to a religious body and is occupied and used in connection with”a building used or occupied solely as the residence of a minister of religion in connection with any such church or building’.
From your post the properties do not have a connection to a church and appear to be used as a Ministers residence for residential accommodation and are not used in connection with a church.
I hope this is helpful.
Regards,
Andrew