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I'd argue that putting the house or garden first is a matter of taste. The rationale given is based on a specific set of preferences. But it's entirely possible other home owners would prioritise the house bc they care which rooms get sun etc and care less abt the garden.
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I think the idea in that snippet is 'there are many more configurations in which the house may be successful, but far less configurations in which the garden may be successful, so design the garden first.' Of course, if the owner cares not for the garden, then that isn't a req!
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