Joint Appeal Lodged By Cllrs Murphy & McEvoy on Donaghcumper

A joint appeal has been  lodged with An Bord Pleanala by Cllr’s Murphy and McEvoy,  the appeal is  against the decision made by Kildare County Council to grant permission for the infrastructure intended to underpin the new town centre development at Donaghcumper.

 

Included in the permission is the demolition  of the boundary wall from the Riding School entrance on the Dublin Rod  to the Abbey Tavern,  however a lower stone wall is to be constructed.   It is expected that planning permission will be sought for high rise buildings behind this low stone wall which will be visible day and night and change completely the historical entrance to Celbridge.

 

 

The decision imposes a condition on the developer to provide a new vehicular  bridge adjacent to  Castletown Gates,  together with  a pedestrian bridge beside  “Kate Walsh’s” old house,   for which separate planning application’s  would be required.   The Councillors question if the conditions imposed in the permission can in fact be delivered and draw attention to the 2007  published accounts for Devondale’s  which indicate a Company Debt of over €147m.

 

The permission also requires the developer to design the traffic signals at both Main Street and at the proposed new entrance (beyond Donaghcumper Riding School entrance).   It appears the design of the traffic signals are required in advance of the design and planning permission for the proposed new bridge at Castletown Gates which the Cllr’s describe as extraordinary.

 

In addition to heritage issues which are at the heart of their appeal,  also included are concerns about flooding.  The piecemeal approach being employed,  with a plethora of individual planning applications,  is causing confusion and infuriating  many citizens of Celbridge the Councillors maintain.

 

Donaghcumper house and demesne are protected and listed on  the national inventory as of National Importance. The demesne is linked to both neighbouring demesnes of Castletown and St Wolstans.    An expert study carried out  by Dr Finola O’Kane and Dr John Olley of UCD’s Dept of Architecture,  Landscape and Civil Engineering  for Kildare County Council in 2006 concluded;

 

“This study has clarified the extraordinary degree of design and planning evident in the composite design of three demesnes; those of Castletown, St Wolstans and Donaghcumper. With their key spinal town of Celbridge they form a remarkable instance of the quality and vision of eighteenth-century landscape design. Research has also suggested that dependency on other linked demesnes; those of Leixlip Castle, Celbridge Abbey and Oakley Park. This composite landscape design is of considerable significance and should be awarded all due protection, recognition and public dissemination….”

 

Tourism based on demonstrable heritage and unique historical character has become a key economic driver in various regions across Europe. The state investment in Castletown House as a jeweled masterpiece offers some Irish equivalence to the continental appreciation of stately homes, castles, forests and parklands.  The setting within the Liffey Valley adds to the appeal in this location.

 

An oral hearing has been requested by Cllr’s Murphy and McEvoy.    The first permission for a traditional housing estate of 108 houses was the subject of an oral hearing last November,   a decision has not as yet been made in this case.




 

Appeal  Below

 

Appeal against decision by Kildare County Council 09/665 to grant planning permission to Devondale Limited, at Donaghcumper Demesne for the following development:

 

The provision of roads and services infrastructure to facilitate the future development of an urban expansion to Celbridge Town centre, set around a new urban street layout, and linked to Celbridge main Street via a new pedestrian bridge. The proposed street layout includes a main avenue road approx. 507m in length, joining the Dublin road at the junction with Shinkeen Road (R405 Link Road), signalized traffic control system and associated reconfiguration of existing carriageway layout at the junction with the Dublin road. Two minor access roads are also proposed off the Dublin Road to provide secondary access to the lands. The pedestrian bridge will be a 35m long single span, steel bridge, providing for a 4.5m wide pathway link from the lands to “George Finney” House (also known as Catherine Walsh house), Main Street, Celbridge (a Protected Structure) with demolition of two out-buildings to rear of house, emerging on Main Street beside Lynche’s Centra shop. Provision is made for future road link from the main avenue to the junction of Celbridge Main Street (adjoining the Parochial House – a Protected Structure) and the Maynooth Road, via a new vehicular bridge over the River Liffey. The proposed development will form a new edge to the north side of the Dublin Road to form a new tree lined avenue entrance to the town in between the Abbey Tavern and existing access gate to Donaghcumper House (riding school entrance), with partial demolition of the existing boundary wall. The development also includes surface water, drainage, foul drainage and water supply infrastructure, associated landscaping all ancillary works, all on site of approximately 6.26hectares etc.

 

Dear Secretary,

 

We wish to appeal against the planning permission granted to Devondale Limited, at Donaghcumper Demesne, Celbridge, Co. Kildare.

 

 

Celbridge a Historical Town

Throughout the Celbridge LAP there are references to the historic character of Celbridge. This is not surprising given the quality and extent of the many protected structures in the town, these include Castletown House and Demesne which is of international importance; Donaghcumper House and Demesne which carries a protection which is of national importance; St Wolstan’s House and Demesne.

 

A linkage between all three has been established by Dr Finola O’Kane Crimmins & Dr. John Olley from the School of Architecture, Landscape and Civil Engineering in UCD in their 2006 document DESIGNED LANDSCAPE OF CASTLETOWN CELBRIDGE AND ADJACENT DEMESNES. This document was commissioned by Kildare County Council in the context of developing an Action Area Plan for Donaghcumper Demesne. The document states on page 27 “This study has clarified the extraordinary degree of design and planning evident in the composite design of three demesnes; those of Castletown, St Wolstan’s and Donaghcumper. With their key spinal town of Celbridge they form a remarkable instance of the quality and vision of eighteenth-century landscape design. Research has also suggested that dependency on other linked demesnes; those of Leixlip Castle, Celbridge Abbey and Oakley Park. This composite landscape design is of considerable significance and should be awarded all due protection, recognition and public dissemination….”

 

In addition there is a cluster of structures including Castletown Gates, the Parochial House, the Church of Ireland, Jasmine House, the Round House etc. all located adjacent to the proposed new bridge linking Main Street to the subject site at the area known as the slip and referred to in condition 4 of planning permission 09/665.

 

While these heritage items are of primary concern to those who enjoy them on a daily basis, the people of Celbridge, many are of such importance that they must be viewed in a national context. If Kildare County Council is not willing to ensure their protection we are appealing to An Bord Pleanála to do so. While this land was zoned for Town Centre extension in 2002 it has remained undeveloped so far. With the advantage of hindsight the Celtic Tiger era can be seen in a proper context, this development is of that era. It was primarily based on speculative development the likes of which we are unlikely to see again. While the permission granted by Kildare County Council 09/665 is for the infrastructure, the cost of its provision would undoubtedly come from large scale development of the kind proposed in the withdrawn planning application 08/438 which provided for 9 blocks of up to 7 story high apartment/retail/commercial development.

 

Within the past week Kildare County Council has arranged to put the Draft County Development Plan on public Display. Included in that plan is the following statement;

“To prohibit inappropriate development within the curtilage and /or attendant grounds of a Protected Structure. Any proposed development within the curtilage and /or attendant grounds must demonstrate that it is part of an overall strategy for the future conservation of the entire complex including the structures demesne and or attendant grounds.”

There is no other view that can be arrived at other than this statement fundamentally conflicts with the decision granted by Kildare County Council. This statement is a repeat of that included in the current County Development Plan.
When seeking additional information on 08/439 currently under appeal the Council stated the following:

9. (a) Given the extent of the development proposed, and given the objective to list Donaghcumper House as a Protected Structure, the applicant should note that the significance of the house and its future preservation is of paramount concern to the Planning Authority. The applicant is requested to submit a strategy for ensuring the ongoing protection of the house, outbuildings and curtilage and note that this should form part of Phase 1 in the Masterplan.

We find it difficult to reconcile the paramount concern of the Local Authority with the decisions they have ultimately made in relation to Donaghcumper. Please also note condition 8 of the permission granted in 09/665 has again sought a strategy for ensuring protection of the house outbuildings etc.

 

In the interim Donaghcumper House and Demesne has been listed for protection by Kildare County Council as follows;

The members noted a report from the County Manager dated 13 March 2009 recommending that, having regard to the architectural, historical and social interest of Donaghcumper House and given its rating of national significance in the National Inventory of Architectural Heritage, in accordance with Section 55(2) of the Planning and Development Act 2000 (as amended) Donaghcumper House and Demesne be added as structure Ref no. B11-54 to the Kildare County Council Record of Protected Structures.

On 18th May 2009 The Department of the Environment Heritage and Local Government wrote to the Council expressing their concerns at the potential of the proposed impact of the development on the character and setting of Castletown House and its designed landscape and on the protected views. They added “It is in our opinion unfortunate that the said lands were rezoned for residential use”.

Section 10 (8) of the 2000 Planning and Development Act states: There shall be no presumption in law that any land zoned in a particular development plan (including a development plan that has been varied) shall remain so zoned in any subsequent development plan.

 

 

Section 10 (8) of the 2000 Planning and Development Act states:

 

When we recently sought to have the Town Centre/Residential zoning on the Donaghcumper Lands reversed the advice from Kildare County Council Officials to the Council was, such a more was likely to lead to litigation and they would not advise it. The draft County Development Plan has just been published and we have an expectation that many submissions will be made to seek such a change in zoning.

 

When we recently sought to have the Town Centre/Residential zoning on the Donaghcumper Lands reversed the advice from Kildare County Council Officials to the Council was, such a more was likely to lead to litigation and they would not advise it. The draft County Development Plan has just been published and we have an expectation that many submissions will be made to seek such a change in zoning.

When there is a conflict between economic and heritage issues it would appear to us that the heritage issues take a poor second place and we question what the phrase “paramount importance” actually means. In the event of this appeal succeeding we respectfully request that the Board comment on the heritage and economic conflicts that have occurred here.

 

 

Demesne Wall to Be Demolished

09/665 permits the developer to demolish much of the Donaghcumper Demesne perimeter wall, if allowed to proceed, it will be replaced by a “new tree lined avenue” between Donaghcumper House entrance on the Dublin Road to the Abbey Tavern. The planning permission seeks the careful dismantling of the wall with the erection of a lower wall provided for.

 

Approach road to Celbridge from Dublin (Lucan)

 

The traditional entrance to Celbridge from Dublin is the first indication that the town has a strong historical character. Not only will the wall be largely removed but the high rise modern mixed development for which a planning application can be anticipated, should this appeal fail, will be exposed and will change the character of the entrance to the town to that of a modern “anywhere” location which would be visible day and night.

 

The Celbridge local area plan sets out to conserve the intrinsic character of the town that of course includes the entrance to Celbridge. (See planning application 08/438 which was deemed withdrawn and also the accompanying EIS and Masterplan for evidence of the type of development intended).

 

 

Process

From the outset the process Kildare County Council adopted placed the public in a less favourable position to that of the developer. When the lands were proposed for zoning in 2002 for example, Donaghcumper was identified in the then Celbridge Development Plan as an area for the extension of Main Street, it was little more than a line on a map, the public were told it would be subject to an Area Action Plan and they would have an opportunity to comment.

 

Public views were eventually sought prior to work commencing on the AAP, however, no public consultation occurred after the publication of the AAP with many of the initial views ignored. The AAP included a requirement for an agreed masterplan prior to any planning application being submitted. In the event the developer ignored this and submitted two separate planning applications (08/438 & 08/439) the latter of which is the subject of an appeal for which an oral hearing occurred in November 2009. We question why Kildare County Council did not refuse permission even on the basis that it was premature pending an agreed masterplan.

 

While the planning application was still live the planning department, including the case planner, worked with the developer towards the completion of the Master Plan. (This was confirmed by the developer at the November oral hearing for planning file 08/439). A masterplan has since been “noted” by Kildare County Council with some outstanding issues earmarked to be dealt with in future planning applications. It is as though this process is primarily occurring between the Council and the developer with the public some sort of remote entity.

 

We submit that a flawed process can produce flawed results, an example being the Corrib Gas debacle. It has been and remains a costly and damaging exercise on all sides.

 

In addition Kildare County Council has a long standing objective for the delivery of a new bridge in close proximity to Castletown Gates, this together with the provision of a Local Area Office, for the Council provided for in the AAP as a “community gain”. Together it creates the impression that the Council are a beneficiary. When taken with a defective process we can’t emphasize more strongly how damaging all of this appears.

 

By granting 09/665 in isolation we are precluded from considering, in the kind of detail that is required, such major issues as school capacity; inadequacy of water supply; public transport; traffic management; visual impacts; scale height mass of future development; social infrastructure assessment; retail impacts particularly on the Main Street etc etc. The key issue for us in this appeal is about the principle of developing in this location. We believe we could have been articulated this more completely had a complete application been made.

 

Furthermore, it is arguable that by granting permissions to piecemeal applications for this environmentally and historically sensitive area, the local planning authority has damaged the impartiality required for each and every future application. The road-layout that is planned to enter the amenity area vested to the County Council ownership requires a full explanation.

 

 

Public Information Session and Public Response

Prior to lodging the two planning application 08/438 and 08/439 the developer hosted a public information session which showed the extent of his proposed development, which included 9 blocks of up to 7 story apartment/retail/commercial, located within Donaghcumper Demesne together with a suburban housing estate, roads bridges etc.

 

This well attended short event outlined the proposals in some considerable detail. There was an immediate adverse public response. All the subsequent planning application’s have attracted substantial numbers of objections, in addition the oral hearing for zone B, a suburban housing estate of 108 houses, which was heard last November, took a full five days. All of this indicates a high level of concern within both the Celbridge and heritage communities.

 

(See Appendix A; this is a briefing by Kildare County Council in Jan 2009 to the joint Celbridge and Leixlip Area Committee’s of Kildare County Council. In January 2009 both planning application were live in fact the draft masterplan had been submitted in response to the additional information request. See page 2 “a draft Masterplan for the Donaghcumper lands has been submitted to the Planning Department. This draft is being considered and a response will issue to the developer on this draft in the near future.” )

 

 

Current Proposal for Infrastructure

The current approval is for roads and other supporting infrastructure and adds to the piecemeal approach which is both confusing and infuriating the local community, it is viewed as the forerunner or the footprint for something similar to what was proposed in the withdrawn application 08/438. This type of development is seen as something from a different era and there is an element of disbelief that there is an insistence to proceed. The heritage arguments are linked with the common good however the economic arguments appear to be winning Council approval.

 

This permission specifies that detailed design of both the pedestrian and vehicular bridges, and approaches to same, shall be subject to separate planning applications. The piecemeal approach means that there is inadequate scrutiny of the vehicular and pedestrian bridges, yet this land zoning in 2002 was for an extension to the Town Centre. If the developer gets several separate permissions it will be the developer who decides the phasing. The permission 09/665 provides that by 1st October the developer shall enter into a legal agreement which will facilitate the delivery of infrastructure for which the costs shall be borne solely by the applicant; these are a) the detailed design of the infrastructure b) the construction of the infrastructure c) the acquisition of lands currently outside the ownership of the applicant required to facilitate the construction d) the relevant statutory procedures.

 

 

While the uses of ‘Grampian Conditions’ are accepted practice in certain circumstances, we have strong concerns regarding their use in the current proposal given:

 

• the number of such conditions proposed,
• the lack of information regarding the likelihood of the relevant infrastructure being implemented,
• the lack of information regarding timescales for such work,
• the consequences in terms of impact on third parties, in particular the riparian owners on the Celbridge Main Street riverbank where the proposed bridges are to be installed.

These concerns are particularly acute in the current economic climate and given that the published accounts of Devondale Holdings Limited (17th July 2008), which indicated debt of €143,279,497 for year ending 31st December 2007.

 

 

Is the proposed bridge in the correct location? Will it cause more delays?

The permission also provides for detailed design of traffic signals at the junctions even before the new bridge is designed or planning permission granted for same, which presumes a positive outcome to a future planning application. The traffic signals for example at Main Street beside Castletown Gates will of necessity be very complicated, we estimate that more than fifteen functions, including pedestrian and a one way in and out through Castletown Gates, will be required. Indeed the original EIS 08/438 & 08/439 estimated that the “New Town Centre” will generate 25,008 daily two way trips. The signals will also hugely detract from the visual appeal of an area where there is a cluster of protected structures. In the absence of a design for these we have no hard data to properly evaluate.

 

All of the above makes us question if this is the correct location for the extension to the Main Street. Indeed a report some years ago done by Shaffrey & Associates indicated the correct location for a new bridge would be on the Clane side of the current bridge. Indeed there are significant lands in the charge of St John of God’s Brothers at St Raphael’s that could have provided an extension to Main Street, St Raphaels would have been open to considering such a proposal in the context of an inclusive proposal for their clients. This could have been done without causing the kind of destruction this current and associated proposals would have on a very sensitive location.

 

 

Flooding

09/665 seeks the following; Surface water shall be retained on site using large attenuation restricting flows to minimum to avoid and minimise flooding. Within days of the oral hearing for 08/439 concluding Celbridge narrowly escaped yet another flood event. We submit photographs taken between 3pm and 4.30pm of that afternoon to demonstrate this. (See appendix B) The Leixlip Dam was opened around 3.30pm to coincide with the river’s tides, this eventually relieved pressure on Celbridge, however, Leixlip was then put on flood alert and some flooding occurred in the neighbouring town as a consequence. Considerable flooding occurred in the low lying Strawberry Beds area later that afternoon. We submit that any development in the Liffey Valley floodplain should be properly evaluated not just for the subject site but also for the cumulative impact such additional developments would produce.

 

The Department of the Environment issued Consultation Draft Guidelines for Planning Authorities in September 2008 on page 33 under the heading
What to do with existing undeveloped, zoned areas at risk of flooding.

4.25 Information about flooding and flood risk is improving and will improve further as a result of national exercises undertaken by OPW and others, and implementation of these guidelines. Future flood risk assessments required to support the development plan process may highlight existing, undeveloped areas which, on their own merits, were zoned for development in previous development plans but which new information indicates may now, or in the future, be at risk of flooding.

4.26 In such cases as set out above, planning authorities should reconsider the zoning objective for any such lands where flood risk is assessed to be potentially significant and likely to increase in the future. This should be done as part of the overall plan preparation and on the basis of the proper planning and sustainable development of the area, giving appropriate weight of flood risk considerations. Following this reconsideration, local authorities may decide to:

 

• Remove the existing zoning for all types of development on the basis of the unacceptable high level of flood risk;
• Replace the existing zoning with a zoning or a specific objective for less vulnerable uses:
• Require preparation of a detailed local area plan, informed by a more detailed flood risk assessment to address zoning and development issues in more detail and prior to any development:…

 

In addition to the floods of November 2009 major damage was done to the town on 9th August 2008 when a major flood event occurred; several housing estates together with the Main Street were under flood. Following this Kildare County Council engaged a firm of consultants (Kilgallen & Partners Consulting Engineers) to draw up a plan to deal with the problem.

 

 

In addition to the floods of November 2009 major damage was done to the town on 9th August 2008 when a major flood event occurred; several housing estates together with the Main Street were under flood. Following this Kildare County Council engaged a firm of consultants (Kilgallen & Partners Consulting Engineers) to draw up a plan to deal with the problem.

 

The report states that damage was sustained on or near Oldtown Road, Church Road, Oldtown Cottages, Scoil na Mainstreach, Celbridge Inner Relief road, The Dale & The Green, Vanessa Close & Vanessa Lawns, St Patrick’s Park, Dara Court and Main Street.

 

 

Of the Main Street the report stated:

“The Main street in Celbridge experienced extensive flooding on 9th August 2008…..Many businesses located on Main Street were flooded…..Reports indicate that water flowed into the premises from the rear and passed through the buildings…..
Clearly there is now a history of flooding in Celbridge to build in the Liffey floodplain may add to problems in the future at the very least there should be a comprehensive evaluation of both the subject site and potential impacts within the catchment.

 

 

Liffey Valley Park

Following considerable pressure from community groups along the Liffey Valley for the preservation of the Valley together with its development as a National/Regional Park similar to the Lagan Valley Park; Government set up a steering group to examine its potential, how it could be managed in an integrated way in respect of its amenity, recreational and heritage resources. The steering group comprised representatives from OPW, Fingal, South Dublin and Kildare County Council’s and Dublin City Council.

 

Eventually a document was produced “Towards a Liffey Valley Park” (appendix C) the purpose of the document is set out in 1.2 as follows:
The purpose of this Strategy is to clearly demonstrate the need to create a management framework for the whole Liffey Valley in one of the few remaining green spaces areas within the Dublin/Mid-East Regions. The surrounding areas have seen extensive population growth in the past decade and there is now an urgent and pressing need to ensure that the valley can function and contribute to recreational and green space facilities for the wider area. In addition the Strategy provides for a process that will lead to the delivery of a Liffey Valley Park.

 

This Strategy presents a Vision for the Liffey Valley as a corridor in its own right but also sets a series of objectives to realize the Vision through building up the public parks and spaces in the Liffey Valley. It proposes this through a series of identified actions and priorities. These are required in order to establish the Liffey Valley as a recognized asset for the benefit of the populations in the surrounding areas. The Strategy is a contribution to the policy making process in regard to the management of the Valley. As such it will help inform the Local Authorities responsible for the Valley.

 

 

Tourism Potential

Tourism based on demonstrable heritage and unique historical character has become a key economic driver in various regions across Europe. The state investment in Castletown House as a jewelled masterpiece offers some Irish equivalence to the continental appreciation of stately homes, castles, forests and parklands. For example, towns such as Versailles and Fontainebleau in France enjoy sensitive preservation in the name of the historical links that underpinned their development. Such connections draw international visitors in ways that could be emulated here in Ireland by invoking links through Jonathan Swift, Arthur Guinness, Arthur Price, William Conolly, etc. While Stratford-Upon-Avon in England has the advantage of Shakespeare’s association, it would not thrive on tourism if the historic buildings were in the shadow of urban canyons, intimidating traffic levels or if they were distant from the rural hinterlands. The surrounding settings are critical to the preservation of their unique character. Preserved towns can take full advantage of architectural features to breathe life into the history that is otherwise restricted to interpretation from books. This fact is not lost on the people of Kildare and the policies adopted by Kildare County Council. We refer you to the Draft County Development Plan for Kildare (2011-2017):

 

12.8.3 Architectural Conservation Areas

 

ACA 1
To investigate the ACAs at appropriate the county to include Celbridge (emphasis added), Kildare Town, Johnstown, Ballymore Eustace, Kilcullen, Brannockstown, Rathmore, Clane and Newbridge.

ACA 2
To ensure that any development, modifications, alterations, or extensions within an ACA are sited and designed appropriately, and are not detrimental to the character of the structure or to its setting or the general character of the ACA.

 

5.8 Sustainable Tourism

 

Tourism is an important sector of Kildare’s economy and it has grown substantially over the last number of years. Kildare has a varied tourism profile, which attracts international and domestic visitors. The natural environment and landscape are significant attractions, comprising the diversity of the flat plains of the Curragh, the bogs to the west, the rolling hills of the eastern uplands, the waterways of the Liffey and Barrow and the Royal and Grand Canals. The rich architectural and archaeological heritage of the county is also acknowledged with many renowned structures and houses including: Castletown House (emphasis added), Carton House, the Wonderful Barn, Moone High Cross and Castledermot Round Tower. Sport tourism, particularly equine and golfing play have an important role in the local economy. In more recent years event tourism and angling have become important elements of the tourist industry. Both the Curragh and Punchestown racecourses hold festivals that attract tourists from all over the world. Key golf clubs include the K Club which hosted the 2006 Ryder Cup, Carton and Palmerstown. It is important to protect and enhance the qualities of such areas so that they can continue to contribute to the growth in tourism visitors into the county as a whole (emphasis added).

 

Within the county there are a number of areas of strategic tourism potential. These are outlined on Map 5.4. Concentrations of tourist attractions are located in and around Kildare town including; St Brigid’s Cathedral and Round Tower, the Irish National Stud, Japanese Gardens, St Fiachra’s Garden and Kildare Town Heritage Centre. There is also a wide range of tourist attractions in the North Kildare Area including, Castletown House and Demesne (emphasis added), Conolly’s Folly, Leixlip Castle and St Patrick’s College Maynooth.

 

These areas have a sustainable and competitive tourism product and have the potential for future tourism growth based on a supply of resources and features around which the tourism product can be built. It is important that tourist development in these areas does not have a negative impact on the overall character of the area.

 

It is arguable that the full potential of a sustainable tourist economy in Celbridge has yet to be sensitively exploited. Evidence can be found in the numbers of local people and visitors that come to enjoy the peaceful settings that are defined by the river valley. The visible character of the village, as viewed by thousands of people the avenue walk on a weekly basis is, enjoys a landscape setting with a natural backdrop of the South Dublin and Wicklow hills. The proposed development would seriously interrupt the natural landscape and similarly alter and impair the future potential for tourism.
Castletown Avenue and the adjacent river valley parkland

 

 

Oral Hearing Request

This planning application and appeal has given rise to immense concern and a huge number of representations in our capacities as elected members of Kildare County Council. We feel that the issues are very complex and given the scale and location of the Applicant’s proposals, the challenge of the concurrent and inter-related planning applications we are respectfully asking for an oral hearing on this appeal.

 

For the reasons stated above we ask the Board to allow this appeal.