GE Governance

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November 2, 2014

Our Great ‘Negotiators’ – Newton, Lipshutz, Hyams, Pilling & Esakoff!

Posted by gleneira under Caulfield Racecourse/C60, Councillor Performance, GE Governance, GE Open Space, GE Planning, GE Service Performance
[16] Comments 

In return for 2046 dwellings (at this stage) which will comprise the Caulfield Village, our great negotiators exacted the paltry sums of 4 and 5 percent as the open space contributions. We estimate that this will provide a return of around $5 to $6 million by the time the money starts rolling in. Similar, long term ‘negotiations’ have taken place over the Moonee Valley Racing Club’s development plans.

Matthew Guy recently gazetted the amendments necessary – declaring the area the equivalent of a Priority Development Zone and, also similar to Caulfield, the creation of an Incorporated Plan approach. An Advisory Committee had been set up to consider the proposals and public hearings were held over ten days. Guy admittedly over-rode many of the committee’s recommendations regarding height and density. However, the following conditions were exacted from the racing club and outstrip by light years what our wonderful negotiating team achieved. We cite directly from the council minutes and remind readers that when queried about the open space within the Caulfield Village development there was no answer forthcoming from our planners and negotiators.

In the end, the Moonee Valley Racing Club were forced to cough up some substantial concessions since council and community worked together. In Glen Eira, residents have to wonder who the negotiating team really worked for? According to the figures below, the Moonee Valley Council can look forward to about $12 million in levies, and countless other millions worth in public facilities. Not so in Glen Eira!

This will allow for the provision of cash and land contributions up to the value of $6,000 per dwelling.

The contributions are to comprise the following:

  • A public open space contribution in the form of a single park equivalent to 5,000 square metres, and additional open spaces up to 2,000 square metres.
  • A financial contribution equivalent to the construction of 2 full sized AFL/Cricket playing fields, including lights and car parking.
  • A financial contribution equivalent to the construction of a 500 square metre sporting pavilion.
  • Delivery/upgrade on-site or off-site for physical and community infrastructure,having regard to the demand generated by the anticipated additional populationwithin the precinct, including:
  • Contribution towards or provision of public art on the site.
  • Financial contributions equivalent to 30% of the construction cost of a Multi-Purpose Community Facility on-site (based on a 500 square metre facility)

Source: http://mvcc.vic.gov.au/~/media/Files/Governance/Council%20meetings/2014/28%20October%20Ord%202014/Agenda%20%20Ordinary%20Council%20Meeting%20to%20be%20held%2028%20October%202014.pdf

 

November 1, 2014

Where Are You Council?

Posted by gleneira under Councillor Performance, GE Governance, GE Planning, GE Service Performance
[14] Comments 

We’ve received a series of photographs that illustrate the carnage caused by development and the failure of this council to enforce its own regulations – much less fine contractors or even order a halt to construction because permit conditions aren’t being adhered to or everyday road rules are ignored. There is absolutely no excuse why residents living near these constructions should have their safety, and lives impacted to such an extent. Developers are not outside the law – but it might appear to some that in Glen Eira they are free to do what they like, when they like, and how they like!

photo13

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photo6 and 7

photo10

photo11

 

photo5

 

 

October 28, 2014

Council’s Broken Record!

Posted by gleneira under Councillor Performance, GE Governance, GE Planning, GE Service Performance
[10] Comments 

Council is clinging desperately to its myth that the new zones are a ‘neutral translation’ of the past. According to their version of history, nothing is different. Well, much is different we say. The number of permits granted since the zones came in have skyrocketed and it’s not due to developers trying to get their ambit applications in before the gazetting of the amendment so that the ‘old’ rules would apply. Nothing is the same under the new zones. The staggering increase of four storey applications for quiet residential streets is a new phenomenon – thanks to the zones. The number of amended permits seeking higher and greater numbers of dwellings is also ‘new’. The current trend of selling multiple blocks of land in order to build bigger and denser apartment blocks is also new. The number of residents getting out of Glen Eira because their streets are becoming the slums of the future is also new. Everything has changed and in our view, to the detriment of thousands upon thousands of residents.

It’s therefore interesting to see in today’s Leader this little ‘clarification’ –

UntitledWe have to ask:

  • What pressure was put on The Leader to insert this token ‘correction’?
  • Isn’t it news that the old system ‘permitted buildings of up to five storeys’ when we are repeatedly told that there were no height limits in the past?
  • Will Council’s reach ever extend to silence real estate agents when they disclose the truth?
 

October 27, 2014

Developers Come Before Residents!

Posted by gleneira under Councillor Performance, GE Consultation/Communication, GE Governance, GE Planning, GE Service Performance
[4] Comments 

At last council meeting Hyams let slip the fact that developers were in the know well before residents had any clue as to what was going to happen on August 5th 2013 – ie the introduction of the new zones.

Here’s some further evidence to substantiate our claim that it is developers who get the ‘inside information’ and residents are the ones left out in the cold – despite numerous public questions as to what was going on in early July 2013.

The screen dump below comes from Ratio Consulting – a big firm that has done plenty of work for developers and has undoubtedly got many ‘friendly’ contacts within council. In a posting dated 30th July 2013 they state the following:

To keep our clients in the loop, here is a summary of what we know so far.  We are mindful that the following information is gathered from verbal discussions from various Department and Council officers as there is little official feedback.  Things are moving quickly so we strongly advise you to make additional enquiries that relate to you and your circumstances.

Many Councils are currently reviewing the zones and the implications and we would expect substantial movement in the next 2-3 months.  We will keep you posted of progress in these municipalities.  The municipalities we do mention below are those we and our clients work with on a regular basis, and/or have information to share.

Source: http://www.ratio.com.au/ratio-news-planning-zones-update

Here’s what is stated about Glen Eira, before the Minister’s announcement on August 5th. We conclude that developers knew more about what was going on within Glen Eira, than residents. Readers will remember that whilst other councils were busily organising their processes for consultation, Glen Eira’s residents had a year of stunning silence. The only item relating to the zones was Council’s submission to the Minister’s draft in 2012 – just on a year before the March 2013 Minister’s announcement that the zones were now set and that they would come into effect on July 1st 2013. This would give councils a year to implement and consult on their proposed zones. For Ratio to therefore state that Glen Eira “is well advanced with the translation of the zones” and that council is ‘working’ with the Department shows exactly how much the big end of town was in the know and how little the ratepayers knew!

ratio

 

October 24, 2014

It’s Never The Zones!

Posted by gleneira under Councillor Performance, GE Council Meeting(s), GE Governance, GE Planning, GE Service Performance
[8] Comments 

At last council meeting a public question asked how many amended permits have been submitted requesting either an increase in height or number of dwellings and how many were granted since the introduction of the zones. The first part of the question remained unanswered. The second part of the question provided the response of only 4 granted permits.

Either council is suffering badly from amnesia, or its record keeping systems are sub-standard, or perhaps the third possibility is that the responses to public questions are far from accurate, truthful, and precise. Somehow, council simply forgot to note one major application that had been decided at the previous council meeting and neatly sidestepped all those applications in commercial zones – admittedly because the question did not specifically refer to this zone.

The argument consistently put up by council is that the zones have had no impact on the increased intensity of development. Not so we argue. With the introduction of the new zones what is starting to emerge is that developers who have clung onto their land (some for several years) are now taking advantage of the ‘largesse’ provided to them via the new zones and submitting amended applications for either increased heights and increased numbers of dwellings. This is even more rampant in the commercial zones where there are no height limits. Below we feature, in addition to the paltry 4 that council nominated, some examples:

150 Tucker Road Bentleigh – Amend Planning Permit GE/PP-21042/2008 by changing the description of what the permit allows/covers to provide an increase of 7 dwellings (from 13 to 20 dwellings) (GRZ1 zone)

259-261 NEERIM ROAD, CARNEGIE – A previous application for a 3-storey building comprising 19 dwellings was approved by the Delegated Planning Committee with a reduction in the number of dwellings to 17 on 8 September 2010. Subsequently, on 11 January 2011, following a VCAT hearing about conditions, the Planning Permit was amended to allow up to 18 dwellings. This permit expired on 8 September 2013.

The current proposal for 28 dwellings is a complete redesign of the approved building with an increased number of dwellings and one additional storey. (RGZ1) (Note: this is technically regarded then as a ‘new permit application’!!!!!

2 MORTON AVENUE, CARNEGIE – Construction of a six (6) storey building comprising forty (40) dwellings, one (1) shop and a basement; reduction of the car parking requirement for dwelling visitors to one (1) car space; reduction of the car parking requirement for the shop to zero; and waiving of the loading bay requirement (Application to Amend a Planning Permit) AND –

A planning permit already exists for the site. The original permit was issued on 14 June 2011. It allowed the construction of a 4 storey building comprising 20 dwellings and a shop. This Planning Permit is still valid and will expire on 14 June 2014. The current proposal for 40 dwellings and a shop is a complete redesign of the approved building with an increased number of dwellings and 2 additional storeys. (C1Z)

467C HAWTHORN ROAD, CAULFIELD SOUTH – Amend the current planning permit to allow an additional storey (total of 4 storeys), provision of a lift and internal alterations. The four dwellings approved under the current permit will not increase in number. (c1z)

356-364 Orrong Road CAULFIELD NORTH – Application to amend Planning Permit GE/PP-22648/2010 which allows a five (5) storey mixed-use building comprising a supermarket, dwellings and a basement car park with an increase in the number of dwellings from fiftysix (56) to sixty-seven (67), an increase in the overall building height by 1.9m, the inclusion of five (5) advertising signs and associated changes to the internal layout and external appearance of the building (c1z)

338A Orrong Road, CAULFIELD NORTH – Amended Application – Amend the permit preamble to allow for a four (4) storey building – was a 3 storey – permit granted on 30/4/2014) (c1z)

670-672 Centre Road BENTLEIGH EAST VIC – Amendment to existing permit as follows – An increase to the size of the building to five storeys – Modifications to the first, second and third floors, including an increase in size and internal changes to the layout of the dwellings – The addition of ten (10) apartments – A reduction to the commercial floor area – (C1Z)

 

October 23, 2014

Johnny Come Lately

Posted by gleneira under Caulfield Racecourse/C60, Councillor Performance, GE Governance, GE Service Performance
[13] Comments 

After years and years of cow towing to the MRC and well after the fact of the Caulfield Village machinations, Cr Lipshutz is now on the side of the angels. Yes, the MRC are ‘bullies’ and yes, the MRC are the tenants and should not be setting their own terms on leases. Well, if this isn’t a Johnny come lately approach we don’t know what is! Only problem is – where was this defiance and public advocacy five years ago?

More to the point is that on today’s Jon Faine program, Lipshutz announced that Council was not opposed to racing and didn’t want training to go from the course! The removal of training is part of the original agreement between council and the MRC. If this position has changed then:

  • Where is the council resolution ratifying such a change in position?
  • If no resolution has been passed then what right does Lipshutz have to make such statements?
  • Or, is all of this again, decision making behind closed doors?

We present below the once lost, but now miraculously found, minutes of a 2008 Trustee meeting where readers will find that the issue of the removal of training was discussed and then subsequently endorsed by council resolution. The full document is then uploaded HERE.

Pages from Trust Minutes 25 September 2008PS: FOR SOME MORE INTERESTING READING, HERE ARE SOME SNAPSHOTS FROM THE MRC’S 2014 ANNUAL REPORT. Please note the reference to Symons as paying ‘commercial rates’ for the training facitilities and for his ‘membership’ of the group but of course, no ‘conflict of interest’ according to our previous post on the Sword claims. The full Annual Report is available from: http://mrc.uberflip.com/i/393091

mrc2AND THE PROFIT EXPECTED FROM CAULFIELD VILLAGE!

mrc

 

October 21, 2014

This Will Not Go Away!

Posted by gleneira under Councillor Performance, GE Governance, GE Planning, GE Service Performance
[5] Comments 

Untitled2Untitled3PS: We also direct readers’ attention to the following snap shot from the latest Annual Report. Please note:

  • ‘Neighbourhood character’ only applies to Minimal Change – in contradiction of council’s own planning scheme!
  • No ‘resolution’ provided to council re introduction of the new zones – simply an ‘implementation report’ – and after the fact of course!

Untitled

 

October 16, 2014

Oh No! – It’s Not The Zones!

Posted by gleneira under Councillor Performance, GE Governance, GE Planning, GE Service Performance
[20] Comments 

Sign at front 79 Bendigo Avenue

79 Bendigo AvenuePS: We forgot to mention that parts of Bendigo Avenue are in a Heritage Zone. A four storey block should do wonders for heritage no doubt and will really fit in with ‘neighbourhood character’. Well done council!

PPS: Here’s a test for council – a double block in a Neighbourhood Residential Zone!

hudson street

 

October 15, 2014

Hanging Out The Dirty Linen & Who Is Telling Porkies?

Posted by gleneira under Councillor Performance, GE Consultation/Communication, GE Council Meeting(s), GE Governance, GE Planning, GE Service Performance
[20] Comments 

Hyams moved to accept the Akehurst report on the new zones ‘as printed’. Sounness seconded.

HYAMS: began by quoting the figures on the influx of new people to Victoria and that ‘obviously they need to go somewhere’. Said that the zones were introduced in 2013 and that Glen Eira had its minimal change/housing diversity from 2003 and that was after ‘at least two years of consultation’. ‘The new zones exactly mirror the old zones’ ‘except for one property in North Caulfield’. Claimed that all that is different is that because of the schedules council has ‘increased the protection to any resident who lives in those zones’ (ie Residential Growth, General Residential Zone and Urban Villages). Repeated that the there’s nothing that developers couldn’t do before. Gave example of an old application in Mavho street that council refused but it went to VCAT and got a permit. But what might have got built before ‘now can’t be built’ because of the height restrictions. Also said that even though there’s a height limit that doesn’t mean that everything will be built ‘to that height’. Therefore there are plenty of developments that previously got permits but now they wouldn’t with the new zones and that includes the RGZ and GRZ zones. Went on to say that there are lots of people blaming the zones for all the new applications but that’s not true because ‘Carnegie has had this sort of stuff going on for a while’ and the same holds for Murrumbeena and Elsternwick where an 8 storey building went up. So all this was happening before and even though ‘they have accelerated’ it isn’t ‘because of the new zones’. But it’s only ‘now that they have reached Bentleigh’ and he thought that it was ‘inevitable that they have spread out from the centre’.

Referred to the argument that council should have ‘consulted’ before ‘bringing in the new zones’. But council wanted to ‘achieve the best possible results’ for the municipality , Claimed that in ‘all’ the discussions with the government it was about ‘convincing them not to expand the high density zones’ and even though they might have wanted to make them smaller ‘no government from either side’ would allow this ‘no matter how much we consulted’. Said that ‘I haven’t heard anything from the ALP on the new zones’ so Labor has ‘no interest in challenging or changing those zones’.

Admitted that post zones there was criticism but this came from the ‘development industry’ about how restrictive the new zones were. Quoted various sources. So by ‘getting in early’ council was ‘able to achieve these height limits’ and ‘other councils haven’t been so lucky’ and Kingston has had their 13.5 metre height limits ‘preferred’ and they are ‘not absolute as they are here’. Government now looks like it’s ‘leaning’ towards higher limits so Glen Eira has ‘done very well’. Thought it was important that people understood the zones and not what some people are saying about ‘encouraging sales’.

SOUNNESS: Said that the report is ‘brief’ but identifies that there are opportunities for development but also ‘tools’ to ‘limit inappropriate development’. Sadly they ‘have to allow development to take place somewhere’ like urban villages and close to transport.

DELAHUNTY: wanted to ask Akehurst a question because the report was basically about neighbourhood residential zones and there were plenty of people ‘here’ who are facing applications not in the residential zones. So she wanted Akehurst to explain how those zones came about and what they mean.

AKHURST: admitted that the paper he wrote was basically about the Neighbourhood Residential Zone but that there are other zones. Said that the Mixed Use Zone is common to all councils and is determined by the government as is the Commercial zones. Neither have height limits and the commercial zones have different uses and explained how these changed with the introduction of the zones.

LOBO: said that height limits ‘sounds good’ but that it is ‘an umbilical cord to the residential zones’. Hyams explained ‘nicely’ how the zones had been ‘transcribed’ from the old zones but in the old zones with minimal change and housing diversity ‘councillors had the option of either accepting or refusing’ as they did with 32 Mavho street where council refused and vcat gave the permit. Said that VCAT doesn’t always ‘get it right’. Said that there is ‘certainty’ but that ‘this certainty is for the builders’ and for ‘real estate agents’ both of whom are ‘laughing to the bank’. (applause). Said that residents vote councillors in and that their role is to uphold what it says on the front of every agenda. Read out the blurb about working in the best interests of residents. Said that he recognises that Ministers have been given ‘carte blanche’ about planning but that ‘we should have gone to consultation’ and at ‘least give a chance’ to people. Said that ‘I asked for it’ and that he ‘voted to be part of the team’ when he was ‘deputy mayor’ and he now thinks ‘I have done wrong’ and ‘mea culpa’. Thought that ‘now we have to do something about it’ and for the next government to ‘do something to repair this damage’. (applause)

OKOTEL: ‘acknowledged’ what Hyams said about ‘direct translation’ of what was there before. However her position was that instead of ‘simply adopt policy’ that ‘council should have engaged in community consultation before making a submission to the planning minister’. (applause) This was because the consultation goes back to 2003.

ESAKOFF: point of order that ‘when I asked about consultation’ she was told that it wasn’t 2003 but 2010.

PILLING: said that the review of the Planning Scheme was in 2010. Said there were 2 consultation: one in 2003 and the last in 2010.

OKOTEL: said that she ‘didn’t feel comfortable’ about not consulting but that she notes that the new zones’ do preserve 78% of the municipality’ and that she does support the report and its comments that ‘compared to other councils’ that Glen Eira’s ‘protections’ are far more than these other councils. But she is also ‘sympathetic’ to the remaining 22% of the municipality ‘which don’t have those protections’ and ‘weren’t invited for consultation’. Even though there are the new zones council still has to ‘refer’ to its policies that ‘require us to look at’ things like Neighbourhood Character. Read out part of a VCAT judgement on an application for Prince Edward Avenue where the member rejected it and said that in terms of Neighbourhood Character it didn’t fit the street even though it was zoned for medium density. Okotel then went on to say that even though there are height limits council still needs to consider policy.(applause)

DELAHUNTY: said she was ‘confused’ about what’s going on. Referred to Hyams and his views about Labor. Said that Brian Tee has made a public statement on the zones and so has the current Labor candidate Nick Staikos who was in chamber. Said that there were ‘conflicting views’ ‘around this table tonight’ and that she was ‘confused’. Said that when they ‘discussed going to consultation’ on the zones and ‘bringing them in quickly’ and ‘with some certainty’ she was ‘certainly on the side of some public consultation’ and ‘I thought I was very much alone there but I’ve got some friends tonight’. Said that the information she got was about the consultation of 2010 and that ‘the arguments’ that were put up then ‘won me over’. Said that in 2010 people wanted ‘height limits and they wanted certainty’. So if the community ‘hasn’t changed’, with the new zones she thought that they were giving people what they had asked for. Post the new zones at a public forum held by LARGE she thought it would be a ‘good idea’ for council to have some public meetings to explain the zones and she remembers ‘being friendless at that time too’. So ‘I am very confused about the sentiments’ being expressed tonight. Wants sensible decisions on the applications before council tonight and hoped that the group could do that. ‘We have to be very careful about saying one thing inside and another thing outside’.

PILLING: supported Hyams and said that ‘these are the correct analyses’. Reminded councillors that ‘this was a unanimous decision a year ago’. The time ‘was to speak out and vote then’ so ‘trying to rewrite history now is a bit rich’. Repeated that it was ‘a unanimous decision fully supported by every councillor here’. Said that 97% of the municipality is protected except for the commercial zones by height limits and Glen Eira is probably ‘the only council in Victoria to have that’. Said that council had been ‘vilified’ by developers and academics but when ‘you get attacked’ by these people then ‘you’ve got the balance about right’. The zones have ‘restricted development into certain areas’. Thought that over time there would be ‘less intense development in these areas’. Said that in Murrumbeena they were applying for 5 storeys and above but now ‘you can only get four’. Repeated Hyams’ words about taking a while to get to Bentleigh but it was inevitable that it would also ‘happen in those areas as well’. Thought that council had done ‘the right thing by the community’ and that ‘we should stand by that decision’. Said that other councils are struggling and that for many it’s a ‘mess’. Said that they had given protection and that it’s something that council ‘should be proud of’ ‘I certainly am’.

Calls from gallery ‘’There’s no democracy’

HYAMS: their aim was to get ‘the best result’. Said that they could have ‘consulted until the cows come home’ and could ‘have gone to the government with anything’ and they would have knocked it back. If they had gone to consultation they ‘would have taken so long to get around to it’ that ‘other councils’ would have got in before them to show how ‘great they were’. If council had waited then ‘we would have got the deal that Kingston or Bayside’ got with ‘larger residential growth zones’. Even though people mightn’t like it ‘we got you the best deal’ and that was by ‘putting popularity’ aside unlike other councils who tried to be popular. He prefers ‘sticking to our decision’ and ‘acknowledging’ that they did the ‘best we could’. Said that in 2010/2011 there was consultation about the whole planning scheme and the results were that people wanted neighbourhoods protected and this was achieved with the Neighbourhood Character Overlays; height limits ‘which we now have’ and ‘transition zones’ and ‘we now have that as well’ via the ‘schedules to the new zones’.

Said that his ‘memory’ is different to Delahunty because he remembers Okotel also arguing for consultation. He also was persuaded that consultation wouldn’t get them a ‘better deal and might get us a worse deal’. Said that there was a ‘rush of applications’ last ‘July and August’ and the reason for this was that ‘all the developers knew that we were about to put these new zones in’ and they knew that what they could get before the zones they couldn’t get with the new zones. So they ‘rushed their developments in’.

GALLERY : how did they know in July when the zones didn’t come in until August?

HYAMS: referred to Lobo’s comments about options to refuse previously. Said he ‘doesn’t follow that’ because they ‘still have all the options that we previously had’. Picked Lobo up about VCAT ‘answering to the Government’ but VCAT ‘independent from the government’. Said that councillors have to carry out their ‘functions’ and that means ‘applying the planning law’. ‘We did the best we could’ and those people who are criticising the zones are doing it for ‘legal purposes’ or ‘have a lack of understanding of planning law’.

OKOTEL: asked a question about ‘adopting the new zones were not unanimous’ and reiterated that ‘my position has always been that we should have engaged in consultation’ and she was never ‘persuaded otherwise’. Said that looking at the minutes of 13th August the ‘achievements’ about height controls ‘was not carried unanimously’ and said that she can’t find ‘the minutes’ relating to the ‘adoption of the zones other than that’.

PILLING: said he would be ‘happy to get the details’ and that it was an ‘unanimous decision by council’

OKOTEL: said that the decision to ‘ratify them’ was unanimous but that the ‘decision to put them to the Minister without consultation was not unanimous’. ‘I did not vote in favour of that’ and repeated that her position was that there should be consultation. (applause)

PILLING: said he would take her question on notice..

MOTION PUT. ONLY LOBO VOTED AGAINST.

 

October 14, 2014

The ‘Zones’ Versus ‘The People’

Posted by gleneira under Councillor Performance, GE Council Meeting(s), GE Governance, GE Planning, GE Service Performance
[11] Comments 

Untitled

Hotham St – 7 storeys 104 dwellings

The Leader Article above referred to the 168 Hotham St. application with 137 objections. There is far more to this application than meets the eye we suspect. Given the magnitude of this proposed development, and its significant location, we believe that residents have the right to know everything that the officer’s report fails to mention, namely:

  • This site was the subject of previous applications
  • This site became Amendment C54 which rezoned the land to a Mixed Use zone (circa 2007-8)
  • A Panel Report was issued
  • The site was (and perhaps still is) owned by Adass Israel and their application at the time involved the construction of 8 shops and 23 dwellings in a three storey building.
  • At the Planning Panel hearing council officers queried the ‘intensity’ of proposed development and traffic management/car parking facilities that were proposed for a mere 3 storey development.
  • The Planning Panel report had plenty to say about height, intensity, etc.
  • Port Phillip council had major concerns about Heritage
  • Ripponlea had major concerns about parking
  • Traffic reports done at the time (2007) stated that Glen Eira Road and Hotham Street had 13,000 and 16,000 cars travelling on these roads daily

Given this history, and the doubts entertained at the time, how on earth can council now turn around and accept a 5 storey building with huge traffic and parking problems– especially when at last council meeting it rejected the Hawthorn Road application for 6 storeys? Where is the consistency? Or have ‘special dispensations’ been handed out to the select few? How many permit extensions has this site received? Or was the permit withdrawn; did it lapse? If either, then why isn’t any of this information found in the planning register? And why, when so many other officer reports include the history of the site is there not one single word about any of this?

lettersrail

 

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