DEC Officer Report

Application No.: 18/01300/A Applicant: Mrs Anna Kawalek Proposal: Approval in principle to replace existing Hotel with five detached dwellings with off street parking Site Address: Groudle Glen Hotel King Edward Road Onchan Isle Of Man IM3 2JY Principal Planner: Mr Chris Balmer Expected Decision Level: Officer Delegation Recommended Decision: Refused Date of Recommendation: 21.12.2020 _________________________________________________________________ Reasons for Refusal R : Reasons for Refusal O : Notes attached to reasons - R 1. The erection of five dwellings on this site would represent an unwarranted development in the Island's countryside and would be contrary to both the land use provisions of the Area Plan for the East 2020 and General Policy 3, Environment Policy 1 and Housing Policy 4 of the Island Strategic Plan 2016. - R 2. The demolition of Groudle Glen Hotel which is a Registered Building given its established historical importance/interest and age and rarity to facilitate the development is considered wholly unacceptable and contrary to Environment Policy 10 and Strategic Policy 4 of the Island Strategic Plan 2016. - R 3. The demolition of Groudle Glen Hotel would result in the loss of the building having substantial connections with the MER and The Groudle Glen Railway as well being a tourist attraction on its own contrary to Transport Policy 3. - R 4. From the information submitted the Department considered the creation of five dwellings on this site would represent an overdevelopment of the site which would adversely affect the countryside/area setting and visual amenities of the area as a whole and Groudle Glen and therefore contrary to Environment Policy 1. - R 5. There is insufficient information to demonstrate that ten off road parking spaces can be provided within the curtilage of each dwelling or that each parking space has or can have the required visibility splay and therefore the proposal would be likely to undermine highway safety contrary to Transport Policy 4 & 7 of the Isle Of Man Strategic Plan 2016. _______________________________________________________________

Interested Person Status – Additional Persons

It is recommended that the following persons should be given Interested Person Status as they are considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 6(4):

The owner/occupier of Glenholme, King Edward Road, Onchan as they satisfy all of the requirements of paragraph 2 of the Department's Operational Policy on Interested Person Status (July 2018).

It is recommended that the following persons should not be given Interested Person Status as they are not considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 6(4):

Manx National Heritage Manx Utilities Drainage IOM Natural History & Antiquarian Society Manx Electric Society The Groudle Glen Railway The owner/occupier of The Old Toll House, King Edward Road, Onchan The owner/occupier of 83 Springfield Road, Baildon, Yorkshire

• As they all do not clearly identify the land which is owned or occupied which is considered to be impacted on by the proposed development in accordance with paragraph 2A of the Policy; are not within 20m of the application site and the development is not automatically required to be the subject of an EIA by Appendix 5 of the Strategic Plan, in accordance with paragraph 2B of the Policy; as they do not refer to the relevant issues in accordance with paragraph 2C of the Policy and as they have not explained how the development would impact the lawful use of land owned or occupied by them and in relation to the relevant issues identified in paragraph 2C of the Policy, as is required by paragraph 2D of the Policy. _____________________________________________________________________________

Officer’s Report

1.0 THE APPLICATION SITE - 1.1 The application site is the curtilage of the Groudle Glen Hotel, which is located on the north side of King Edward Road in Onchan. - 1.2 It should be noted that since this application was initially submitted; the Department has formally entered the building onto the Registered Buildings list. The registration was unsuccessfully appealed, therefore the building remains a Registered Building. - 1.3 The Groudle Glen Hotel, King Edward Road, Onchan was Registered for the following reasons: "HISTORIC INTEREST:

• * The Groudle Glen Hotel is an important surviving building of the Groudle Glen, a 19th century pleasure glen developed by Richard Maltlby Broadbent for the developing tourist industry. Age and rarity:
• *The Groudle Glen Hotel is a surviving building associated with a Glenside development created as part of the island's 19th century tourist industry."

2.0 THE PROPOSAL - 2.1 The planning application seeks approval in principle to replace existing Hotel with five detached dwellings with off street parking. Only the principle of five dwellings is for consideration at this stage. All other matters are reserved.

2.2 The planning application submission comprises the application form, a location plan defining the site by red line, a drawing of showing the existing layout of the building, a drawing showing an illustrative layout of five detached dwellings; proposed elevation and sections of the five dwellings; proposed floor plans; a supporting statement setting out the applicant's justification for the proposal; and supplementary statement in response to representations received (dated 7th February 2019).

3.0 PLANNING HISTORY - 3.1 Whilst the application site has been the subject of previous planning applications it is considered that only the following are specifically material to the assessment of this current planning application: - 3.2 Application for the de-registration of the former Groudle Glen Hotel (19/00287/REGBLD) in accordance with 7(1)(a) of the (Registered Buildings) Regulations 2013 -19/00510/CON REFUSED at Appeal on the following grounds:

"R 1. Following assessment of the application, taking into account the reasons put forward and considering these against the statutory requirements and the Operational Policy it is concluded that the information provided in the application is not sufficient to warrant deregistration of the building which is of architectural and historic interest."

• 3.2.1 The Planning Inspector concluded that: "Conclusion

• 65. I conclude, on balance, that the Hotel possesses sufficient special architectural and historic interest, in terms of the relevant legislation and guidance, to justify its continued inclusion in the Protected Buildings Register and that this appeal for its removal from the Register should therefore not succeed.
• 66. Finally, with respect to the proviso of the Operational Policy that for buildings dated after 1860, as in this case, progressive selection is necessary due to the larger numbers of buildings erected and surviving, I have seen no reasoned comparison with specific examples elsewhere on the Island to divert me from my conclusion that the appeal should fail."

3.3 Approval in principle for conversion of existing building into permanent and or tourist apartments and provision of associated off road parking facilities - 13/00531/A - APPROVED

- 4.0 PLANNING POLICY

4.1 In terms of local plan policy, the application site is located within an area not designated for development or within a settlement boundary; within Area of Predominant Woodland or Trees; all under the Area Plan for the East 2020.

4.3 In terms of strategic plan policy, the Isle of Man Strategic Plan 2016 contains a number of policies that is considered specifically material to the assessment of this current planning application. - 4.4 Strategic Policy 4 states: "Proposals for development must:

• (a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings(1), Conservation Areas(2), buildings and structures within National Heritage Areas and sites of archaeological interest;
• (b) protect or enhance the landscape quality and nature conservation value of urban as well as rural areas but especially in respect to development adjacent to Areas of Special Scientific Interest and other designations; and
• (c) not cause or lead to unacceptable environmental pollution or disturbance."

4.5 Environmental Policy 1: "The countryside and its ecology will be protected for its own sake. For the purposes of this policy, the countryside comprises all land which is outside the

• settlements defined in Appendix 3 at A.3.6 or which is not designated for future development on an Area Plan. Development which would adversely affect the countryside will not be permitted unless there is an over-riding national need in land use planning terms which outweighs the requirement to protect these areas and for which there is no reasonable and acceptable alternative."
• 4.6 Environment Policy 4 states: "Development will not be permitted which would adversely affect:

• (a) species and habitats of international importance:

• (i) protected species of international importance or their habitats; or
• (ii) proposed or designated Ramsar and Emerald Sites or other internationally important sites.

• (b) species and habitats of national importance:

• (i) protected species of national importance or their habitats;
• (ii) proposed or designated National Nature Reserves, or Areas of Special Scientific Interest; or
• (iii) Marine Nature Reserves; or
• (iv) National Trust Land.

• (c) species and habitats of local importance such as Wildlife Sites, local nature reserves, priority habitats or species identified in any Manx Biodiversity Action Plan which do not already benefit from statutory protection, Areas of Special Protection and Bird Sanctuaries and landscape features of importance to wild flora and fauna by reason of their continuous nature or function as a corridor between habitats.

Some areas to which this policy applies are identified as Areas of Ecological Importance or Interest on extant Local or Area Plans, but others, whose importance was not evident at the time of the adoption of the relevant Local or Area Plan, are not, particularly where that plan has been in place for many years. In these circumstances, the Department will seek site specific advice from the Department of Agriculture, Fisheries and Forestry if development proposals are brought forward."

4.7 Environment Policy 30 states: "There will be a general presumption against demolition of a Registered Building. In considering proposals for demolition or proposed works which would result in substantial demolition of a Registered Building, consideration will be given to:

• o the condition of the building;
• o the cost of repairing and maintaining it in relation to its importance and the value derived from its continued use (based on consistent long-term assumptions);
• o the adequacy of efforts made to retain the building in use; and
• o the merits of alternative proposals for the site."

4.8 General Policy 3 states: "Development will not be permitted outside of those areas which are zoned for development on the appropriate Area Plan with the exception of:

• (a) essential housing for agricultural workers who have to live close to their place of work; (Housing Policies 7, 8, 9 and 10);
• (b) conversion of redundant rural buildings which are of architectural, historic, or social value and interest; (Housing Policy 11);
• (c) previously developed land which contains a significant amount of building; where the continued use is redundant; where redevelopment would reduce the impact of the current situation on the landscape or the wider environment; and where the development proposed would result in improvements to the landscape or wider environment;
• (d) the replacement of existing rural dwellings; (Housing Policies 12, 13 and 14);
• (e) location-dependent development in connection with the working of minerals or the provision of necessary services;
• (f) building and engineering operations which are essential for the conduct of agriculture or forestry;

• (g) development recognised to be of overriding national need in land use planning terms and for which there is no reasonable and acceptable alternative; and
• (h) buildings or works required for interpretation of the countryside, its wildlife or heritage."

4.9 Housing Policy 4 states: "New housing will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(1) of these towns and villages where identified in adopted Area Plans: otherwise new housing will be permitted in the countryside only in the following exceptional circumstances:

• (a) essential housing for agricultural workers in accordance with Housing Policies 7, 8, 9 and 10;
• (b) conversion of redundant rural buildings in accordance with Housing Policy 11; and
• (c) the replacement of existing rural dwellings and abandoned dwellings in accordance with Housing Policies 12, 13 and 14."

4.10 Transport Policy 3 states: "New development on or around existing and former rail routes should not compromise their attraction as a tourism and leisure facility or their potential as public transport routes, or cycle / leisure footpath routes." - 4.11 Paragraph 11.2.5 of the IOMSP states: "The Island is fortunate to have an historic vintage rail network, which includes the Isle of Man Steam Railway, the Manx Electric Railway, the Snaefell Mountain Railway, the Groudle Glen Railway and the horse trams which run along Douglas Promenade. Development on or around the rail network should not compromise its attraction as a tourism and leisure facility or the potential for increased use as a public transport system, for example as a means of travelling to work." - 4.12 Transport Policy 7 states: "The Department will require that in all new development, parking provision must be in accordance with the Department's current standards."

The relevant standard for apartments is currently 1 space for 1 bedroom and 2 spaces for 2 or more bedrooms.

- 5.0 REPRESENTATIONS

5.1 Onchan District Commissioners recommend (08.01.2019) that the planning application be refused on the grounds of overdevelopment of the site and does not comply with the Onchan Local Plan 2000 sections O/RES/P/20 and O/RES/P/22.

5.2 The Department of Infrastructure Highways Division does not oppose (05.02.2020) the planning application although questions whether there is room for five dwellings; they also comment that a Reserved Matters application would need to ensure adequate visibility's splays for a speed limit of 40mph, driveway spaces to comply with 'Manual for Manx Roads' ; the current plans show inadequate visibility splays and some driveway spaces that are too short, too narrow and do not take into account of the increased width needed adjacent to boundary structures. - 5.3 The Arboricultural officer (DEFA) makes the following comments (14.01.2020): "…At the eastern end of the site this proposal would likely lead to the removal of a large conifer (Chamaecyparis sp.) and palm adjacent to the glen entrance, as their retention would be impractical. I would not object to the removal of these trees as they are not specimens of note and they do not make a significant contribution to the amenities of the area. These trees are not marked on any of the submitted plans.

To the north of the site there are 3 trees recorded on drawing 16-2524-02-A. I believe there is another large mature broadleaf tree to the west of this group which has been missed off the survey.

• At the western end of the site drawing 16-2524-02-A shows that there are 2 sycamore trees and 1 lime tree immediately adjacent to the northern boundary. The western most sycamore has been removed (under licence) due to the damage being caused to the boundary (and retaining) wall. The proximity of the tree marked as a lime (which is in fact an elm) to the western most dwelling makes it likely there will be future pressure to the remove the tree, even if it could be protected during construction; however, due to the potential for damage to the nearby retaining wall, I probably wouldn't object to this tree being removed at some point in the future. I do not object to this application but, in the event that it is approved, request that a condition is applied requiring the submission of a tree protection plan with a future reserved matters application.

e.g. The reserved matters shall include a scheme for the protection of the retained trees (a tree protection plan) on and adjacent to the site which shall be prepared in accordance with the recommendations of British Standard BS5837:2012 (Trees in relation to Design, Demolition and Construction - Recommendations)."

5.4 Manx Utilities Drainage comment (28.01.2019) that drainage arrangements will remain private at all times and not be considered for public adoption by Manx Utilities. - 5.5 Manx National Heritage (17.01.2019) objects to the application which can be summarised as (please note comments made before the building was Registered); while not Registered is likely to be to been designed by the Arts & Craft Architect M H Ballie-Scott; while the building has been altered in the past the building remains recognisable; apparition takes no account of the significant of the building or no justification for its demolition; it features in postcards and photographs almost as soon as it was completed and is an importance part of the character and setting of the Glen; the density of the proposed development of five dwellings is excessive in this setting and have negative impacts when vied form the Glen; the building is suitable for bats to roost; number of trees are mature and have potential for bat roosting and birds nests; if approved a bat and bird surveys be undertaken. - 5.6 IOM Natural History & Antiquarian Society (20.02.2019) objects to the application which can be summarised as (please note comments made before the building was Registered); building is proposed to be Registered; Groudle Glen is an important tourist attraction due to its location to the MER line; contrary to Transport Policy 3, Landscape Proposal 10; Landscape Strategy Area D3; Onchan Local Plan Polices; previous application was approved to convert the building the fact this was not followed up by a detailed application means that it has very little relevance to the current application; current proposal is not in compliance with any Strategic Plan Policy; and No structural survey or economic statement has been submitted to show the building could be returned to operate as an hotel/restaurant. - 5.7 Manx Electric Society (07.02.2019) objects to the application which can be summarised as (please note comments made before the building was Registered); designed by the Arts & Craft Architect M H Ballie-Scott; the building was built at the terminus of the then Douglas and Groudle electric tramway it is therefore an icon representing one of the earliest pioneering interurban electric tram lines; Groudle remains an un spoilt stations; Groudle is an interchange between two important heritage lines and the replacement of the Groudle Glen Hotel with a modern development will undermine the pleasure of visitors to both as an un-necessary intrusion in an otherwise timeless journey from the tramway to the Groudle Glen Steam Railway; development would deplete the atmosphere of the only remaining photo stop on the tramway; and the building is historically important to tourism and should be retained for the pleasure of visitors and residents. - 5.8 The Groudle Glen Railway objects to the application which can be summarised as (please note comments made before the building was Registered); building is a intrinsic part of the unique history of the glen; proposal is an excessive development which could

• fundamentally alter the character of the Glen area; effect the visitor appeal of both the Manx Electric Railway and the glen itself; designed by the Arts & Craft Architect M H Ballie-Scott and it loss would be to the local area and the island's heritage; unique tourist attraction often commented by visitors ro the railway around the world and its loss would erode the history and ambience of the glen; the proposal would be wholly out of character for this unique and historic setting; concerns of highway safety; concerns of issues relating to the sewerage system in the area; and rear elevation from the glen would not at all be in keeping with other properties.
• 5.9 The owner/occupier of Glenholme, King Edward Road, Onchan objects (10.01.2019) to the application which can be summarised as (please note comments made before the building was Registered); requires the demolition of a historic building; would result in the loss of mature trees; the density of properties is not in keeping with the area; and proposes parking is dangerous so close to the blind bend and due to volume of traffic.
• 5.10 The owner/occupier of The Old Toll House, King Edward Road, Onchan, Onchan objects (22.01.2019) to the application which can be summarised as (please note comments made before the building was Registered); application makes no reference to the continued responsibility in providing a sewerage system for the residents of Groudle; and what would have to the current system.
• 5.11 The owner/occupier of 83 Springfield Road, Baildon, Yorkshire, objects (06.06.2019) to the application which can be summarised as (please note comments made before the building was Registered); This iconic property has enhanced the location there for,many years and I support its retention ; five modern dwellings would be wholly out of place at this location with its wonderful Tram Stop and with its entrance to a Manx national Glen; proposal would be a scar in the Groudle landscape.

- 6.0 ASSESSMENT

6.1 The main material considerations to consider is the principle of five new dwellings; the acceptance of the demolition of a Registered Building; potential visual impacts upon the landscape/area/Glen; potential highway safety matters; and Drainage Matters.

Principle of five new dwellings

6.2 Fundamentally, in terms of planning policy there is a long established presumption against new residential development in the countryside. As identified earlier within the planning policy section of this report, this presumption against is set out in a number of different ways. Firstly, the application site is not zoned for residential development under the recently adopted Area Plan for the East which has designated sufficient land for residential development elsewhere. Accordingly, not only is the land not designated, but it is not required to meet housing demands as more appropriate land has been designated elsewhere in existing sustainable settlements. Secondly, General Policy 3 of the Isle of Man Strategic Plan, states that in such areas new dwellings will generally not be permitted. Thirdly, the site is not identified in an adopted Area Plan as being within a town, village, or within a sustainable urban extension and therefore contrary to the exceptions indicated in Housing Policy 4. The site is also not within the settlement boundary of Onchan under the Area Plan for the East. Fourthly, the site is within a countryside location and therefore Environment Policy 1 requires consideration. This policy indicates that the countryside and its ecology will be protected for its own sake, unless there is an over-riding national need in land use planning terms which outweighs the requirement to protect these areas and for which there is no reasonable and acceptable alternative. The proposal fails this policy also.

6.3 The proposed dwelling does not serve a viable agricultural holding; and while not an existing dwelling and therefore there are no special circumstances to warrant the setting aside of the presumption against. The development proposed by this planning application is therefore clearly contrary to the current policies of the Department.

6.4 Any argument that as approval was grant to convert the building into 6 apartments should in effect allow five new dwellings on the site is flawed. Housing Policy 11 which considers the conversion of rural buildings into residential accommodation requires a number of requirements, one being the building is of; "architectural, historic, or social interest". When such proposals are approved they are considered exceptions to general policy which seeks to restrict development which is on land not designated for development. Paragraph 8.10.2 of the IOMSP also states:

"Conversion of such buildings into dwellings can make a useful contribution to the housing stock, ensure retention of our built heritage, and improve the appearance of what might otherwise become derelict fabric."

6.5 Accordingly, approval of a conversion of a rural building into one or more dwellings is approved as an exception, due to the above reasons. It therefore does not follow that once approved (albeit six apartments wasn't implemented in this case) and the works completed, that the Department would then considered the converted units replacement, with new dwellings being acceptable. The Department does not. - 6.6 Approval of such a scheme would set a significant precedent for similar types of development through the countryside in the Isle of Man. The purpose of the planning system is to control the use and development of land in the public interest. That requires a consideration of what is most appropriate for the population of the island as a whole. The protection of the Manx countryside from development and the presumption that new housing should be directed to locations consistent with the principles of sustainable development are two of the most important themes running through the Strategic Plan, the purpose of which is to establish a consistent framework within which the public interest can be served by the planning system. When making a planning decision that has permanent consequences (such as the erection of five dwellings as is proposed here). - 6.7 Therefore, this application like the majority of applications the Department receives each year for new dwelling/s in the countryside, should be refused for being contrary to strict and established planning policy which seeks to protect the countryside from development. Furthermore, it is important; that such development is controlled by the development plan process rather than as ad hoc decisions taken in isolation. The acceptance of the demolition of a Registered Building - 6.8 It is clear from the recent appeal for the de-registration of the former Groudle Glen Hotel (19/00287/REGBLD), that the building is of historical importance/interest and Age and Rarity. The proposal would seek to demolish a Registered Building which has very recently been considered at an appeal and concluded that it should be retained as a Registered Building. Accordingly, the proposal is contrary to Environment Policy 30 and Strategic Policy 4. - 6.9 Furthermore, Environment Policy 30 states:

"There will be a general presumption against demolition of a Registered Building. In considering proposals for demolition or proposed works which would result in substantial demolition of a Registered Building, consideration will be given to:

• o the condition of the building;
• o the cost of repairing and maintaining it in relation to its importance and the value derived from its continued use (based on consistent long-term assumptions);
• o the adequacy of efforts made to retain the building in use; and
• o the merits of alternative proposals for the site."

6.10 Even if the land was designated for development; the Department would have concerns of approving the current application for the Approval in Principle for a replacement building/s; as the application does not include any significant details or evidence in answer to those issues

• listed above. Further, at this stage the Department has no detailed plans to consider the "the merits of alternative proposals for the site"; as the application is an Approval in Principle and the submitted plans/elevations are indicative only at this stage. Overall, it is considered the demolition of the Registered Building is unacceptable and contrary to Environment Policy 30.
• 6.11 A further element of the principle of the demolition of the Registered Building is clearly the historical significant that has been outlined by the Groudle Glen Railway, Manx Electric Society , IOM Natural History & Antiquarian Society & Manx National Heritage; that the loss of the building having substantial connections with the MER and The Groudle Glen Railway as well being a tourist attraction on its own. The proposal would result in this inter linked attractions being reduced and therefore the proposal is considered contrary to Transport Policy 3. Potential visual impacts upon the landscape/area/Glen;
• 6.12 There are significant concerns of the proposal for five dwellings. The submitted plan show indicated dwellings of a row of 1930's styled dwellings. Whilst there is a similar property near to the site; this is an individual property which has been in place for many decades. To replicate this is considered to be out of keeping with the area and the countryside location. Generally for replacement dwellings in the countryside the Department would consider Planning Circular 3/91 (i.e. Manx Farmhouse style property) and Housing Policy 14 which refers to Planning Circular 3/91 and also indicated replacements of dwelling of innovative modern design may be acceptable. In this case the proposals as shown would fail these policies. It should be noted however, there is no planning policy design for new dwellings in the countryside, as there is a presumption against such development.
• 6.13 While there are five indicatively designed dwellings shown; these could be changed at a Reserved Matters Stage. However, there is significant concern that a row of five dwellings (however they are designed on a site which has tight constraints) would be out of character with the area, introducing a more suburban feel and would adversely affect the countryside/area and also have adverse impact on views from the adjacent glen, all contrary to Environment Policy 1 of the IOMSP. Furthermore, the Department is not comfortable at this stage that the site is of a size to accommodate appropriate levels of parking spaces (discussed further in report), dwelling internal space, amenity space, landscaping etc. The indicative plans submitted do raise concern of an overdevelopment of the site. Potential highway safety matters
• 6.14 Highway Services have indicated that the principle of five dwellings maybe acceptable, albeit the information submitted does not demonstrate parking spaces as shown are of a size to be considered acceptable and the visibility splays as shown are not acceptable. Whilst the application is an Approval in Principle only and matters of access are not matters for consideration now; the Department needs to be comfortable at this stage, that 5 dwellings each with two off road parking spaces can be reasonable be achieved. At this stage the Department is not. As the space of the site for five dwellings is limited, the knock effect is that four out of the ten spaces shown are not within the curtilage of each dwelling, rather located west boundary of the site. Drainage Matters
• 6.15 It is noted there is an existing drainage issue associated with the site and neighbouring properties. This matter would need to be considered at a detailed Reserved Matters stage to ensure appropriate drainage concerns can be overcome.

- 7.0 CONCLUSION

7.1 For these reasons outlined within this report it is considered the proposal would be contrary to Environment Policy 10, Environment Policy 30, Strategic Policy 4, General Policy 3, Housing Policy 4 & Transport Policy 3 and 7 all of the Strategic Plan and the Area Plan for the East 2020 of the Strategic Plan and therefore recommended for an refusal.

- 8.0 INTERESTED PERSON STATUS

8.1 By virtue of the Town and Country Planning (Development Procedure) (No 2) Order 2013 (Article 6(4), the following persons are automatically interested persons:

• (a) The applicant, or if there is one, the applicant's agent;
• (b) The owner and the occupier of any land that is the subject of the application or any other person in whose interest the land becomes vested;
• (c) Any Government Department that has made written submissions relating to planning considerations with respect to the application that the Department considers material
• (d) Highway Services Division of Department of Infrastructure and
• (e) The local authority in whose district the land the subject of the application is situated.

8.2 The decision maker must determine:

• o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and
• o whether there are other persons to those listed in Article 6(4) who should be given Interested Person Status.

8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status.

I can confirm that this decision has been made by the Director of Planning and Building Control in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded Interested Person Status.

Decision Made : Refused Date : 22.12.2020 Determining officer Signed : J CHANCE Jennifer Chance Director of Planning and Building Control

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