The South Hams Society objected to a proposal to build a house on a highly prominent hillside within the South Devon Area of Outstanding Natural Beauty, which would have caused harm to the scenic landscape quality of the AONB and the protected coastline. The planning aplication has been turned down by South Hams District Councillors.
Here is the Council Planning Officers Report and the decision.
PLANNING APPLICATION REPORT Case Officer: Jacqueline Houslander
Parish: East Portlemouth Ward: Stokenham Application No: 2107/18/OPA Agent: Mr Michael Stopher Stopher Design Partnership Ltd 56 Fore Street Kingsbridge TQ7 1NY Applicant: Mr & Mrs Brettel Millbay Cottage East Portlemouth TQ8 8PU Site Address: Millbay Cottage, East Portlemouth, TQ8 8PU Development: Demolition of existing building and construction of new replacement dwelling with associated parking relocated on the site
Reasons for refusal
1. The proposed dwelling is in a location where new residential development is not permitted unless it can be justified on the basis of agricultural or forestry grounds or that it is meeting a need which cannot be met in a settlement. The proposal provides no such justification and is therefore contrary to policy DP15 of the Development Policies DPD; Policy TTV31 of the emerging JLP and paragraph 79 of the NPPF 2018.
2. The proposed replacement dwelling is not justified because of the lack of a lawful use of the existing dwelling; it is substantially larger than the existing dwelling and it is located some 80metres away from the position of the existing dwelling, contrary to Policy DP17 of the Development Policies DPD; Policy TTV32 of the emerging JLP.
3. The proposed dwelling would be located on a highly prominent hillside within the South Devon Area of Outstanding Natural Beauty, which would cause harm to the scenic landscape quality of the AONB and as such would be contrary to policy CS9 of the South Hams Core Strategy and Policy DEV 24 and DEV27 of the emerging Plymouth and South West Devon Joint Local Plan as well as paragraph 172 of the NPPF 2018
4. The site is steeply sloping and insufficient information has been submitted to demonstrate that the proposed dwelling can be appropriately drained, both in terms of surface water drainage and foul drainage. Without that information the Local Planning Authority cannot be assured that the drainage will not impact on other areas, as such it is contrary to the development plan policies CS11 in the Core Strategy, DP4 in the Development Policies DPD and DEV37 in the emerging Joint Local Plan, as well as advice contained within para. 162 of the NPPF 2018.
Key issues for consideration: Principle of development Location of development Impact on the AONB and landscape and ecology Size and scale of development Financial Implications (Potential New Homes Bonus for major applications): It is estimated that this development has the potential to attract New Homes Bonus of £1187.00 per annum, payable for a period of 5 years. Members are advised that this is provided on an information basis only and is not a material planning consideration in the determination of this application.
The application site is at East Portlemouth, on a piece of land which is the curtilage to a property known as Millbay Cottage. Currently there are two properties on the site, the cottage itself together with an attached smaller property. The site where it is proposed to place the replacement dwelling is on quite steeply sloping land, with an access road, which also serves another property (Bay House) curving around such that the site lies between the two parts of the access road as it climbs up the slope. The site does not lie within any defined development boundary The site lies within the South Devon AONB. It is also in the area designated as Heritage Coast It is in an area where Cirl Buntings are located. The River over which the site looks is part of an SSSI. The Proposal: The proposal is to replace a dwelling which is attached to Millbay Cottage with a new dwelling further along at the end of the garden – land which is currently scrub.
Consultations: County Highways Authority: No comments
Environmental Health Section: Town/Parish Council: REASONS FOR REFUSAL: 1. This is effectively a new dwelling in open countryside because it would replace an existing ancillary flat associated with Millbay Cottage 2. This new dwelling would no longer be an ancillary dwelling 3. The proposal is in the AONB and Heritage Coast location 4. There will be considerable visual impact in a sensitive area due to the disproportionate size of the development.
The application is supported by a Preliminary Ecological Appraisal (PEA) and Bat Activity Appraisal (both in 2018 by Colin N Wills), considering the presence of protected species and habitats, and the implications upon them from the proposed demolition of the existing dwelling towards the south of the site, and erection of a new dwelling towards the north of the site. The PEA notes that ‘The majority of the Site is woodland garden, with small areas of tended garden set amongst maturing broadleaved trees. The woodland and green lane to the east are strong ‘linear features’ linking different habitat areas.’ Evidence of/potential for use of the site by reptiles, amphibians and nesting birds was recorded. The site was found to ‘support low numbers of common species of bat which feed around the woodland edge throughout the night, the adjacent woodland-garden and green lane are used by individual Greater and Lesser Horseshoes on an infrequent basis only.’ No evidence of roosting bats was recorded in association with the Boathouse. The findings of the ecology surveys are not such that would preclude the site being developed, however there are various findings that will need to be reflected within any subsequent Reserved Matters application. Notably in terms of impact avoidance/mitigation measures that will need to be Reflected at the detailed design/layout stage, the ecology reports highlight a requirement for:
A hedgerow along the boundary with the driveway to Bay House to reduce light spill and maintain a dark entrance to the green lane and associated woodland habitats. Ensuring no illumination from the SW elevation of the proposed dwelling onto the old driveway which runs through the woodland-garden, as this could deter Lesser and Greater Horseshoe Bats which have been recorded there. And more generally mitigation to include: Sensitive lighting scheme (including internal lighting given the likely degree of glazing typically associated with a proposed dwelling in this type of location), and consideration of light spill reducing glass types/coatings. Native hedge planting and landscaping. Inbuilt bat roosting and bird nesting opportunities within the proposed dwelling, and features for reptiles within the garden. Appropriate approach to construction with respect avoiding/minimising impacts on bats, birds and reptiles. Recommendation: No objection subject to conditions
Conditions securing the following: A sensitive lighting scheme at Reserved Matters, including a lux modelling plan of light spillage from internal and external sources to 0.5 lux – this should be developed in dialogue with a consultant ecologist. A Landscape and Ecological Mitigation and Enhancement Strategy at Reserved Matters incorporating measures from 2.2 of the Bat Activity Appraisal and 4.4 of the PEA and a Reptile Method Statement. (The LEMES should include impact avoidance, mitigation and enhancement proposals for construction and operational phases, and be fully integrated with any Landscape Details/Scheme and should demonstrate net gain in biodiversity). Drainage: We are no longer providing formal responses for the following applications that meet the Low and Medium risk criteria. • House Holder • Replacement dwelling & Change of use. • Small scale minor (1-2 units) Please look at the relevant guidance document on the website and assess accordingly. The guidance is arranged by application type, and identifies the requirements for each risk group.
Having reviewed the guidance this development would be a medium risk site and would be required to submit some drainage information. Please see analysis below: Representations: Representations from Residents Comments have been received and cover the following points: Object:
The application site and proposal is in a highly sensitive AONB, CPA, County Wildlife Site and Heritage Coast location, outside of settlement boundaries. As far as can be ascertained, the existing dwelling is a small flat (annex) above a double garage…… the claim that this dwelling is 130 square metres in floor area should be open to public scrutiny, given that the Development Plan seeks proportionate scaled replacements. the proposed replacement dwelling is totally disproportionate to the existing dwelling it replaces, contrary to policy.
The Council must be certain that Millbay Cottage Flat lawfully is a separate dwelling, perhaps with an Electoral Roll check. There are no signs of a separate address, post box, a shared access arrangement outside the front door of the cottage and no private grounds. Land Registry records show it as within the same title.
The proposal involves demolition of the flat and garage and erecting a large dwelling nearly 80 metres north west, overlooking Kingsgrove Both existing and emerging Development Plan policy is clear that roughly the same footprint should sought for replacement dwellings. Clearly this proposal is totally at odds with the Development Plan
The South Hams Society Objected for the following reasons:
The proposal to demolish the existing boathouse/flat which is located some distance away from the footprint of the proposed replacement dwelling is contrary to policy TTV32 – residential extensions and replacement dwellings on the countryside. The proposal is contrary to policy DP17
The AONB should be given great weight in decision making and the impact of a development on the wooded slopes of the valley side is a significant intrusion on the landscape The SHS support guidelines that set out to protect and sensitively interpret the coastlines outstanding geological features, which includes protection of the undeveloped coastal plateaus, avoiding the siting of new development and vertical structures on prominent skylines, which would be highly visible.
The SHS are also deeply concerned on a site which is protected by LNR and SSSI designations, will adversely affect the surrounding habitats. Undeveloped connectivity on the upper Millbay slopes is essential to the migration and sustainability of birds, bats, amphibians and reptiles.
The proposal is contrary to TTV31; TTV32; DEV20; DEV24; DEV27 The sparsely developed wooded slopes above Millbay present a unique setting of stunning visual amenity which must be protected for the enjoyment of future of generations.
Relevant Planning History 20/0664/01/F: FUL Proposal Demolition of two dwellings and construction of one dwelling Site Address Millbay Cottage East Portlemouth Salcombe TQ8 8PU Decision Conditional approval: 10 Jan 02 Appeal HEA: Upheld (Conditional Approval): 10 Jan 01 20/0283/05/F: FUL Proposal Amendment to planning permission 664/01 to change boat and gear store to swimming pool and games room with provision for winter boat storage Site Address Millbay Cottage East Portlemouth Salcombe Devon TQ8 8PU Decision Conditional approval: 04 Apr 05
ANALYSIS Principle of Development/Sustainability: The first consideration for this proposal is whether the location of the site. It lies in an area which does not benefit from a defined development or settlement boundary and so as such is within the area which would be defined as open countryside. Policy DP15 in the South Hams Development Policies DPD presumes against development in the countryside unless it is justified on the basis of wither agricultural need, forestry need or it is providing for a need which cannot be met within any defined development boundary. The proposal meets none of these criteria and so as such is contrary to this policy. Policy TTV31 in the emerging Joint Local Plan is a similar policy and presumes against development in the countryside unless…Housing and employment development adjoining or very near to an existing settlement will only be supported where it meets the essential, small scale local development needs of the community and provides a sustainable solution.
2. Isolated development in the countryside will be avoided and only permitted in exceptional circumstances, such as where it would: i. Meet an essential need for a rural worker to live permanently at or near their place of work in the countryside and maintain that role for the development in perpetuity, or ii. Secure the long term future and viable use of a significant heritage asset, or iii. Secure the re-use of redundant or disused buildings and brownfield sites for an appropriate use.
3.. Secure a development of truly outstanding or innovative sustainability and design, which helps to raise standards of design more generally in the rural area, significantly enhances its immediate setting and is sensitive to the defining characteristics of the local area. In this case the proposal does not meet these criteria. It is therefore also contrary to emerging planning policy. Until recently, some of the development plan policies have been deemed to be out of date as they preceded the 2012 NPPF which had a presumption in favour of sustainable development. However since that time the more recently adopted NPPF 2018 has come into being and it has added a new provision in relation to not only housing land supply but also based on delivery of housing. The report for South Hams has just been released and based on both housing land supply and also housing delivery, it has now been deemed that the South Hams does in fact have a 9 year housing land supply. As a result of this new dwellings in the countryside not closely associated with a development boundary are subject to much more stringent scrutiny than in the recent past. The following paragraphs provide the detail behind the recently published Housing Delivery Test.
Housing Delivery Test (HDT)& 5 Year Housing Land Supply}
When determining applications for residential development it is important to give consideration to housing supply.
Paragraph 73 of the NPPF stipulates that “Local planning authorities should identify and update annually a supply of specific deliverable sites sufficient to provide a minimum of five years’ worth of housing against their housing requirement set out in adopted strategic policies or against their local housing need where the strategic policies are more than five years old””
Paragraph 11 of the NPPF states that “plans and decisions should apply a presumption in favour of sustainable development” including applications involving the provision of housing. It also states (paragraph 11(d):“Where there are no relevant development plan policies, or policies which are most important for determining the planning application are out-of-date [the planning authority should] granting permission unless: i. The application of policies in this Framework that protect areas or assets of particular importance provides a clear reason for refusing the development proposed; or ii. Any adverse impacts of doing so would significantly and demonstrably outweigh the benefits, when assessed against the policies in this Framework taken as a whole.”
Footnote 7 of paragraph 11d of the NPPF explains that policies which are most important for determining the application are considered out-of-date where the local planning authority cannot demonstrate a five year supply of deliverable housing sites (with the appropriate buffer as set out in paragraph 73 of the NPPF); or where the HDT indicates that the delivery of housing is substantially below (less than 75% of) the housing requirement over the previous three years. Under the transitional arrangements set out in annex 1 of the NPPF the HDT 2018 result triggers the provisions of NPPF paragraph 11d if the HDT result is below 25% not 75%.
It should be noted, however, that the Local Planning Authority is at an advanced stage in the preparation of the Plymouth and South West Devon Joint Local Plan. The pre-submission version of the JLP has been formally approved by Plymouth City Council, West Devon Borough Council and South Hams District Council and has since been submitted to the Planning Inspectorate for Examination, pursuant to Regulation 22 of the Town and Country Planning (Local Planning) (England) Regulations. Guidance on the amount of weight to be applied to the JLP is contained elsewhere in this report.
The ‘Housing Requirement’ set out in the Adopted Core Strategy (2006) is now considered to be out of date. The NPPF/NPPG/Housing Delivery Test (HDT) measurement rulebook makes clear that ‘Housing Requirements’ in adopted plans that are more than 5 years old are to be considered out of date. The Housing Requirement set out in the JLP is yet to be adopted. NPPG makes clear that the Government’s new HDT and 5 year land supply applies to South Hams LPA until adoption of the JLP using the new standard methodology establishing Local Housing Need (LHN).
South Hams’ 2018 HDT result is explained and set out in the JLP authorities Housing Position Statement together with the 2018, 5 year land supply position for South Hams LPA. South Hams LPA’s 2018 HDT result is anticipated to be 191%. There are therefore no policy consequences and a 5% buffer only is required for the South Hams LPA 5 year housing land supply.
Current National Policy and Guidance requires LPA’s to use the latest household projections (2016) when deriving the Local Housing Need for Plymouth. The Government has also recently consulted on revising the NPPF/NPPG to stipulate that the latest household projections (2016) are not to be used and that the LHN should be derived using the previous Household Projections (2014). This however is not the current National Policy position until such time as the NPPF/NPPG is revised accordingly. The JLP authorities Housing Position Statement therefore sets out the 5 year land supply position for the South Hams LPA against South Hams’ Local Housing Need derived from both sets of projections. The Housing Position Statement explains in paragraphs 6.19 and 6.20 that Plymouth LPA can demonstrate a net deliverable supply of 3,093 dwellings over the period 20182023. This represents 9.4 years supply when set against the LHN derived using the 2016 Household projections and a 9.1 years supply when set against the LHN derived using the 2014 Household projections. As South Hams LPA can now demonstrate a 5 year land supply the tilted balance in favour of sustainable development (as set out in paragraph 11d of the revised NPPF) is not triggered for the purpose of deciding this application.
Upon adoption of the JLP the JLP authorities Housing Position Statement will be updated to reflect the 5 year land supply position against the housing requirement in the JLP and how this is to be monitored. In this case the proposal therefore fails to meet the policy and emerging policy relating to housing development in rural areas. The proposal must also be considered against policy DP17 in the Development Policies DPD and also Policy TTV32 in the emerging Joint local Plan, which relates to replacement dwellings Both policies are the same and essentially seek to ensure that proposals to replace a dwelling in the countryside will be permitted provided that the existing dwelling has a lawful use for permanent residential use and has not been abandoned; The size of the new replacement dwelling will not be significantly larger than the original house volume; The number of new dwellings is no more than the number of dwellings to be demolished and replaced; Any new replacement dwelling should be positioned on the footprint of the existing dwelling, unless on design, landscape, highway safety, residential amenity, or other environmental grounds a more appropriate location can be agreed. In this case the lawful use of the second dwelling is unsubstantiated and not proven. There is no planning history relating to the erection of the dwelling or indeed the erection of any other building. As a result it is not possible to say with the information submitted whether the second dwelling has a lawful use.
The size of the replacement is larger than the existing potentially unauthorised dwelling, and whilst it is smaller than a previous proposal is still significantly larger than the one it is supposed to be replacing. It is proposed to replace one for one. The proposed replacement is some considerable distance from the one it replaces. It is therefore considered that the proposal fails to meet policies DP17 and TTV32.
Design/Landscape: The site lies within the South Devon AONB and Heritage Coast. Policy CS9 in the South Hams Core Strategy identifies the importance of the AONB designation. It states that great weight shall be given to the AONB. The proposal is to place the replacement dwelling on a prominent slope overlooking the beach and the Salcombe Estuary. There are clear views to it from the river, across at Salcombe and also from the public footpath which runs along the road. It is also on land which has not been developed on before and so would be a new intrusion into the landscape.
The general area has a number of residential properties dotted around the Creekside, most of which are at a lower level. Higher up the slopes the properties are far less frequent. The proposal is large and is unprotected by trees which are heavily planted in other areas. It would be a significant visual intrusion into this very sensitive protected landscape. The proposal would thus fail to meet policy CS9, Policy DEV 27 in the emerging JLP and also would not have regard to the NPPF 2018, paragraph 172. Neighbour Amenity: Whilst there are no immediate neighbours to the proposal site, the property above could be affected by virtue of shared use of the access lane. In addition being that the proposed dwelling is at a higher level than the properties around the creek side, there is potential for overlooking. However there have been no LOR’s relating to loss of residential amenity.
Highways/Access: The Highway Officer has not made comment on this application. The proposed access is above the proposed dwelling off an existing access track which serves Bay View. Given the sloping nature of the land, there would need to be a considerable amount of excavation needed in order to secure a driveway and turning space as well as parking spaces. Whilst from a highway safety point of view it may not cause harm, it would be yet a further degradation of the natural beauty of the area and would be harmful to that scenic beauty.
Ecology: Two surveys have been carried out and it is noted that they acknowledged that the site was a likely habitat for reptiles. A further more detailed bat survey was carried out and noted that there were no roosting activity on the site itself and that whilst opportunistic feeding may occur a development could be carried out which would still allow for this activity to continue. The Council’s ecologist reviewed the surveys noting the above and suggested conditions should be imposed if the proposal was accepted. As there are potential mitigations in relation to the ecological value of the site for the proposed dwelling and this is a recommendation for refusal, it is not considered appropriate to add an ecology reason for refusal.
Drainage: A Foul sewerage drainage assessment was submitted in support of the application. Because of the more minor nature of the development the Councils drainage expertise offered standing advice. That advice states the following: Non-Mains Sewage Assessment Where connection to the mains sewer is not practical, then the foul/non-mains drainage assessment will be necessary to show why the development cannot connect to the public mains sewer system and show that proposed system follows the foul drainage hierarchy as set out in the FDA1 form. A non mains foul drainage assessment should include a full assessment of the site, its location and suitability for storing, transporting and treating sewage. If the proposed development results in any changes/replacement to the existing system or the creation of a new system, scale plans of the new foul drainage arrangements will also need to be provided. This will include a location plan, cross sections/elevations and specification of the equipment used. The main plant will need to be 7m away from the dwelling and the drainage field should be 15m from a dwelling. New Discharges to dry ditches are not permitted and if discharging to a water course the treatment plant should conform to BS EN 12566. Foul Drainage Assessment form (FDA1) must be completed and include any supporting information and testing. The proposals should comply with the General binding rules and you need to check the EA maps to see if the site is within Source Protection Zone 1 and if an Environmental Permit is required. Whilst a foul drainage assessment was submitted it did not contain any additional information and no testing had been carried out. There is therefore insufficient evidence to determine whether a foul drainage solution can be provided on the application site. In relation to surface water drainage it states the following: Medium risk sites are not within flood zone 2 and 3 or a CDA but may not have sufficient space available to provide an indicative drainage solution, or the site is steeper than 1:10. Discharging to a water course or public sewer could be offered as an ‘in principle’ scheme. Any discharge to a public sewer will also require written permission form SWW. A drainage assessment will be required to identify a practical drainage solution and give reasons why that particular option has been selected. In accordance with Development Policy DP4 and where space permits, SuDS should be considered which address water quality and offer low maintenance for the life of the development. Drainage assessment – medium risk The drainage assessment needs to evidence how roof water and surface water shall be managed for the development. For these smaller developments full SuDS schemes can be impractical so a practical approach can be taken if the following drainage hierarchy for sustainable development is achievable. 1. Soakaways/infiltration systems 2. Controlled/attenuated discharge to watercourse 3. Storm water/combined sewers In this case, no surface water drainage information has been included on the drawings. The application form indicates that surface water will be dealt with via sustainable urban drainage. No further detail has been provided. Whilst the proposal is in outline, it is still relevant at outline stage to consider whether the site can accommodate adequate drainage facilities. The site is quite steeply sloping and no percolation testing has been undertaken at this stage. In which case the proposal fails to demonstrate that surface water or foul drainage of the site is possible. It is therefore proposed to add a drainage reason for refusal.
Conclusion: The site lies in the countryside with no justification. It is also a replacement dwelling where the lawfulness of the existing building has not been proven, the replacement is also substantially larger than the existing and the location of the replacement dwelling is some way away from the original and so the proposal is contrary to the replacement dwelling policies. In addition the proposal is on a site within the South Devon AONB and Heritage coast, which is very prominent and it is considered that the impact on the AONB would be severe. The severity of the impact of the proposal would be made worse by the need for excavations to form an access and parking area on the site, which would require extensive excavations. In addition the proposal contains insufficient information in relation to both foul and surface water drainage. It is recommended for refusal. This application has been considered in accordance with Section 38 of the Planning & Compulsory Purchase Act 2004.
Planning Policy Section 70 of the 1990 Town and Country Planning Act requires that regard be had to the development plan, any local finance and any other material considerations. Section 38(6) of the 2004 Planning and Compensation Act requires that applications are to be determined in accordance with the development plan unless material considerations indicate otherwise.
The relevant development plan policies are set out below:
South Hams LDF Core Strategy CS1 Location of Development CS7 Design CS9 Landscape and Historic Environment CS10 Nature Conservation Development Policies DPD DP1 High Quality Design DP2 Landscape Character DP3 Residential Amenity DP5 Conservation and Wildlife DP7 Transport, Access & Parking DP15 Development in the Countryside DP17 Residential Extensions and Replacement Dwellings in the Countryside South Hams Local Plan (please delete as necessary) SHDC 1 Development Boundaries Emerging Joint Local Plan The Plymouth & South West Devon Joint Local Plan is currently undergoing a main modifications consultation (22 Oct – 03 Dec 2018) as part of the examination in public to determine the soundness of the plan. The National Planning Policy Framework provides guidance on the weight that can be given to policies in emerging local plans in paragraph 48:
48. Local planning authorities may give weight to relevant policies in emerging plans according to:
a) the stage of preparation of the emerging plan (the more advanced its preparation, the greater the weight that may be given);
b) the extent to which there are unresolved objections to relevant policies (the less significant the unresolved objections, the greater the weight that may be given); and
c) the degree of consistency of the relevant policies in the emerging plan to this Framework (the closer the policies in the emerging plan to the policies in the Framework, the greater the weight that may be given)
The JLP is nearing the conclusion of the examination process, and can be considered to be at an advanced stage of preparation.
Whilst technically all objections are unresolved until the Inspectors’ issue their Final Report, some policies which did not receive objections at the Reg 19 stage could be given very significant weight. The nature and scope of objections made regarding each policy have been taken into account when determining the weight to be apportioned to each emerging policy.
The Council consider that the emerging policies are all compliant with the NPPF. It should be noted that the JLP is being examined against the provisions of the 2012 NPPF, and therefore for the purposes of paragraph 48 of the NPPF policies should also be assessed for their conformity against the 2012 NPPF. In considering the merits of this proposal, case officer recommendations are informed by the weight that can be attributed to emerging JLP policies and adopted development plan policies, as well as the degree of conformity with the new NPPF. PLYMOUTH AND SOUTH WEST DEVON JOINT LOCAL PLAN -: PUBLICATION (as considered by the Full Councils end Feb/Early March 2017) SPT1 Delivering sustainable development TTV31 Development in the Countryside TTV32 Residential extensions and replacement dwellings in the countryside DEV24 Landscape character DEV25 Undeveloped coast DEV27 Nationally protected landscapes DEV28 Protecting and enhancing biodiversity and geological conservation Neighbourhood Plan There is no current neighbourhood plan in place in this area.
Considerations under Human Rights Act 1998 and Equalities Act 2010 The provisions of the Human Rights Act 1998 and Equalities Act 2010 have been taken into account in reaching the recommendation contained in this report. DELETE THIS SECTION IF A COMMITTEE REPORT The above report has been checked and the plan numbers are correct in APP and the officers report. As Determining Officer I hereby clear this report and the decision can now be issued.
Name and signature: J houslander
Chairman of Planning Committee – Cllr Steer Date cleared – 21/12/18 first draft agreed. 3/1/19 second draft agreed Comments made – happy to delegate having read your report.
Ward Member – Cllr Brazil Date cleared – 20/12/18 first draft agreed 2/1/19 2nd draft agreed. Comments made – Agree refusal.
Ward Member – Date cleared Comments made