Farrants Way – The Inspector’s Report
Report of an Inquiry opened on 25 April 2001 into an application by the Department of Local Government and the Environment for planning approval for the erection of 80 apartments and associated car parking on land at Farrants Way, Castletown.
|The Inquiry was held under the provisions of Schedule 1 Section 8, of the Isle of Man Planning Scheme (Development Plan) Order 1982, as amended.
|At the opening of the Inquiry about 20 objections had been received. Those objecting to the proposed development include:
J A Brown MHK, Castletown Commissioners, Castletown Heritage, Castletown Chamber of Trade and Commerce, The Department of Education and a number of individual businesses and local residents.
|The main grounds of objection were, the proposed development was out of character with neighbouring development, over development and loss of parking. Other objections include, the development is contrary to the provisions of the Development Plan, loss of amenity in terms of outlook and loss of sunlight, lack of amenity and play space, traffic, pre?maturity and the effect of the proposal on the Primary School.
|This report includes a description of the site and surroundings, the gist of the submissions made, my conclusions and recommendation. Lists of appearances and documents are attached.
|SITE AND SURROUNDINGS
|The land the subject of this application is a corner site at the junction of Farrants Way and Scarlett Road, Castletown with an area of some 0.8 hectares (2 acres). The site is generally level, with frontages to Farrant’s Way, Scarlett Road and Scarlett Close and otherwise bounded by the rear boundaries of mainly single storey, dwellings fronting Kissack Road and the boundaries of 2?storey dwellings fronting Scarlett Close.
|A substantial area at the eastern end of the site close to the junction of Farrant’s Way and Scarlett Road is used for informal parking. The remainder of the site is largely unused.
|Neighbouring development south west of Farrant’s Way is predominantly residential, comprising mainly one and two storey dwellings. However, south east of the junction with Scarlett Road an electricity sub station and the Castletown Fire Station front onto Farrants Way. There is also a grassed open area of land fronting the south eastern side of Scarlett Road between areas of houses.
|On the northern side of Farrant’s Way, opposite the application site, the back gardens and yards of generally 3 storey commercial and residential properties within the Castletown Town Centre, back onto this part of the road. There is also a Church, and a supermarket and the Castletown Town Hall and Library front the road, opposite the south east corner of the site at the junction with Scarlett Road.
|Development on both sides of Farrant’s Way is generally set well back from the road, creating an air of spaciousness.
|THE CASE FOR THE APPLICANTS
The material points were:
Housing Policy Background:
|The Isle of Man Government Policy Review 2000, Volume 2 page 63, paragraph 17.2.2 puts the Department under an obligation to implement the recommendations of the Housing Policy Review Report 1999. This requires the Department to facilitate the construction of up to 400 new housing units per annum over the next 5 years, including 80 first time buyers’ properties and up to 80 public sector housing units per annum.
|The target for new housing is currently under review to take account of an increase in immigration and other factors. The Department regards housing to be its number 1 priority and its policies have been endorsed by the Council of Ministers.
|Most new housing on the Island is provided by the private sector. The role of Government is to take measures, when appropriate to stimulate demand at the lower end of the market by releasing land in public ownership and by making financial incentives available to bring the cost of housing within the reach of more people.
|The Department is in the process of releasing land in other parts of the Island, but has no land in Castletown. Financial incentives are provided to residentially qualified applicants on low incomes, through the House Purchase Assistance Scheme 1999, as amended by the House Purchase and Refurbishment (Amendment) Scheme 2000, approved by Tynwald on 12th July 2000.
|The Department has held discussions with developers and invited them to come forward if they have land zoned for residential purposes and are interested in a joint scheme for the provision of first time buyer’s housing which satisfies the conditions set by the Department.
The Register of first time buyers introduced in April 2000 identified 43 persons specifically interested in housing in the South. By April 2001 this figure had increased to 56. The Housing Progress Report of June 2000 revealed that the Castletown Town Commissioners’ waiting list for public sector housing for rent in Castletown was 54. This now stands at 52 and is in addition to the 56 persons on the Register of first time buyers not accepted on the waiting list because they could afford to purchase their own homes. This gives an indication of the wider, housing needs in the area.
The Farrant’s Way Proposal:
|This application was submitted by DOLGE because of the proposed 80 apartments, 15 would be made available for first time buyers.
|The construction of new housing units on this land at Farrant’s Way, which is zoned for residential purposes, would provide a small but extremely important contribution towards meeting the housing targets endorsed by Tynwald and the need for housing in Castletown.
|The proposed development comprises 80 apartments constructed on 3 and 4 levels with car parking arranged on 2 levels in a courtyard at the rear and landscaping. Vehicular access into the site would be from Farrant’s Way and a public open space with seating would be provided facing the Castletown Commissioners’ Office at the junction of Farrant’s Way and Scarlett Road.
|Planning Policy and Land Use Considerations:
|The site is designated for residential development in the Isle of Man Planning Scheme (Development Plan) Order 1982 and the Castletown Local Plan ? Circular 5/91 confirms that designation. Paragraph 5.5 of the written statement states, “An area bounded by Farrant’s Way and Scarlett Road is suitable for residential development.”
|Policy 5.8 further states, “It is considered that the site bounded by Farrant’s Way and Scarlett Road should be developed for residential use allied to car parking although a limited degree of commercial development may be required to ensure the viability of the scheme.”
|The Castletown Local Plan is being reviewed and a Draft Written Statement was produced in January 2001. Policy C/RES/P/10 requires development of the application site to be undertaken in accordance with an approved layout for the whole site and new dwellings must be of a form and positioning to respect the amenities of existing dwellings bordering the site.
|Policy C/CP/P/5 identifies a site on the southern side of Scarlett Road to be suitable for use as a public car park subject to a formal layout and planting to soften the appearance of the site.
|The next stage of the Plan process, the publication of the Draft Written Statement for consideration at the Public Inquiry, will not occur until the summer of 2001.
|The site is situated outside the Castletown Conservation Area. However, views into and out of the Conservation Area remain an important consideration in any development proposals.
|There is an extant Planning consent for the erection of an office building on the site, which expires on 17 October 2001. Planning approval was granted for 21 dwellings and associated car parking on the site on 5 February 2001. This approval is the subject of Review.
|Planning approval was granted on 9a’ March 2001 for an area of land south of Scarlett Road to be used as a public car park with controls. This approval is also the subject of Review.
|The site lies immediately outside the Castletown Conservation Area and is separated from it by Farrant’s Way an inner relief road, lacking any enclosure or place. There is a distinct sense of physical separation.
|Buildings within the Conservation Area vary in height, generally being 2 or 3 storeys. The use of roof spaces to provide accommodation, expressed as dormers or roof lights is common. Buildings within the suburban area are generally one or 2 storeys and again the use of roof space is common especially in the single storey dwellings.
|From the assessment of the site and its relationship to the Conservation Area the following design strategies were established:
|The development should enhance, and not detract from the historic town centre.
|The development should be generally urban in character.
|The development should have height and mass in keeping with the height and mass of the town centre.
|The development should form a transition zone between the town centre and the adjoining residential area by gradual reduction in height and scale and the provision of attractive aspects both to the town centre and to the residential area.
|The external aesthetic treatment should draw on familiar forms, details and materials whilst not being a pastiche of the existing buildings.
|The architectural style is based upon details and elements observed within the town centre and the buildings would be subdivided within, into 7 separate groups of apartments arranged to face both inwards and outwards.
|The development takes the same general form and massing as that envisaged by the two most recent planning approvals on the site. An outline approval for a mixed development (94/0848) and an approval in detail (94/1482) for part of that development in the form of a 2 and 3 storey office building on the corner of Farrant’s Way and Scarlett Road. The storey height of the new office building generally exceeds that of the residential development by 1 m.
|The proposed buildings are arranged around the site perimeter to provide street frontage to Farrant’s Way and Scarlett Road. This provides enclosure to the space at the rear in which 115 parking spaces are provided, 40 of which are underground and all accessed from Farrant’s Way.
|The buildings are 2 storeys in height plus accommodation in the roof space, rising to 3 storeys plus accommodation in the roof space, close to the junction of Farrant’s Way and Scarlett Road. The upper storey is characterised by dormers, roof lights and roof terraces. The height of the buildings is comparable to the height of buildings with equivalent storey height in the centre of Castletown.
|There are no objections to the proposal from the Department of Local Government and the Environment, the Department of Transport, the Fire Authority or the Drainage Authority.
|The gable end of the block facing the rear of No. l Kissack Road would be set back to permit the provision of a landscaped area and a footpath and the upper levels would be faced with decorative panels to avoid the appearance of a bland gable. The apartment block adjacent to Scarlet Close would be 3 storeys including one storey in the roof space. Overshadowing would be time limited and not significant and the proposed development would have no significant effect on the amenity of neighbouring residents.
|Lifts would ensure that almost 75% of the units, including those with ground floor access would be accessible by wheelchairs and disabled persons. Parking spaces adjacent to each entrance would be designated for disabled use.
|The density of the proposal is a consequence of the urban design strategy and is therefore greater than in suburban areas. The internal courtyard is overlooked by more than half the apartments, which will discourage unwanted intrusion. The proposal includes an element of open space, which enhances the open space in Scarlett Close.
|The site is currently used as a free car park and has been so for some considerable time. However this use is completely unauthorised and there is no requirement or guarantee that this use will continue. This application provides for sufficient car parking to meet the needs arising from the development itself.
|Planning approval has been granted for a new public car park on the south side of Scarlett Road. Subject to proper management, that and the other available public car parking facilities within and adjacent to Castletown will continue to meet local needs.
|The proposed development would have no adverse effect on the Castletown Conservation Area. Indeed the proposed development would introduce a feature of architectural importance and significance within the local townscape, effecting a visual transition between the historic core of Castletown and the suburban residential development to the west.
|OBJECTIONS – THE GENERAL CASE FOR THE OBJECTORS
The material points were:
|Development Plan Provisions
|The Castletown Local Plan adopted in 1991 confirms at paragraph 5.7 that the site is suitable for residential development. However, Policy 5.8 states that, the site `should be developed for residential use allied to car parking, although a limited degree of commercial development may be required in order to ensure the viability of the scheme.’
|The Castletown Plan, Draft Written Statement January 2001, Policy C/RES/P/3 states, `Encouragement will be given to the use of vacant plots within the existing residential and mixed use areas for new housing where appropriate. Such schemes must be in keeping with existing buildings and must not compromise the amenities of existing residents.’
|Status of Policy Reviews and Reports
|Tynwald has not endorsed the Departments and Governments housing policy/strategy as indicated by the applicants.
|The Policy Review 2000 Report and the Policy Review 1999 Report were approved by Tynwald as follows:
“That Tynwald approves the Review as a statement of policies and endorses, as a general strategy, the provisional programme of legislation, revenue and capital expenditure and other initiatives contained therein.”
|The Housing Policy Review Report 1999 and the Housing Progress Report 2000 were `received’ by Tynwald, not `endorsed’ as suggested.
|The need for housing in Castletown and the need to provide housing for first time buyers is acknowledged and accepted. This is not a matter in dispute.
|Nevertheless, whilst there is no doubt of the priority the Government give to the provision of housing, especially for first time buyers, they do not consider that housing should be provided at any price. This was recently demonstrated by the rejection by a substantial majority of the `Housing (Special Provisions) Bill’, which sought to amend planning law to enable planning legislation and policies to be set aside specifically to enable first time buyers’ houses to be built on 3 sites. The Bill was opposed by the Minister for Local Government and the Environment along with his Department and the Council of Ministers.
|Castletown needs first time buyer homes urgently but not in an inappropriate development, which would be intrusive and alien to the town.
|The Proposed Development
|The proposed development of 80 apartments, 3&4 storeys high would be an over intensive use of this two acre site, out of keeping with this area of Castletown. The development of this one site would be more intensive than any site in the town. On its own it would increase the residential stock of the town by some 6.5% and provide almost half of Castletown’s housing requirements up to 2011. The proposed density would seriously stretch the infrastructure of the area such as schools and health services and add to the existing traffic circulation problem.
|In particular Victoria Road Primary School has no unused classrooms and additional pupils can only be accommodated by increasing class sizes. The Department of Education’s capital programme contains a scheme to extend the school with completion envisaged in 2005. The proposed development would be likely to generate about 17 children of primary school age. This would create difficulties for the school and result in the need for a mobile classroom or Tynwald approval to bring forward the Department’s Capital Scheme.
|The proposed development would be contrary to the adopted Castletown Local Plan as it does not incorporate parking for public use. Furthermore the units would not be suitable for first time buyers with small children or planning families. There is no recreational space suitable for small children and due to the nature of the proposal would involve a considerable service charge.
|The development would also be contrary to Policies C/RES/P/3 and C/RES/P/10 of the draft Local Plan as it is not in keeping with existing buildings in this area and certainly compromises the amenities of existing residents. The height, mass and scale of the building would be out of scale with neighbouring housing and excessively intrusive to neighbouring residents, particularly those in Kissack Road.
|Farrant’s Way forms an important boundary between the old part of Castletown with its two, three and four storey buildings and this part of the town which has been developed over many years since the mid 1960’s with one and two storey dwellings.
|The proposed development would have an immense and overpowering impact on the neighbouring area, destroy the ambience of the low?lying style of development and should not be permitted.
|Loss of Car Parking
|The application site is the last town centre site zoned for residential and car parking development. Due to its location the development of the site is of the utmost importance to the town and its future viability as a business centre.
|Castletown has a varied business sector consisting of retail, leisure services, offices and heritage sites and considerable investment has been undertaken by the private sector, Central and Local Government to secure the town’s viability following the decline of the 1960’s and 70’s.
|There is a current shortfall of about 200 parking spaces in the central area and unless the need for parking is met Castletown will decline as a business centre. Many traders are in danger of collapse; several shops are already vacant and others have been converted to residential use. About 15/20,000 sq. ft of office space is also vacant.
|In the Issues and Options Document published in May 2000 the Department of Transport indicated a full Traffic and Parking Study for Castletown would be desirable and that a site close to the retail centre of town should be identified for future parking.
|The land the subject of this application has been utilised as a public car park for over 15 years. It continues to be used daily by some 50 to 60 vehicles and substantially more at peak periods, which demonstrates the need for parking space within the town. The total loss of public car parking from this site would have a serious and irreversible consequence on the town’s business sector.
|Some years ago the owner gave specific permission to Castletown Town Commissioners for the land to be utilised, under their supervision, as a free public car park. The Commissioners have erected a sign on the land to advise that the area is available for car parking.
|Some 10 years ago, due to concern at the lack of available public parking in the town centre, the Castletown Town Commissioners approached the owner with a view to purchasing the land for the provision of a town car park. The owner refused to sell but agreed to the continuing use of the site for public parking.
|It has been acknowledged since before the adoption of the Castletown Local Plan, Planning Circular 5/91, that the land the subject of this application should have dual residential and public car parking uses for the benefit of Castletown. Referring to the site, the Local Plan Inspector stated in his report, `It is in a good position to provide car parking which is needed in the central area’ and went on to say it could also be used for first-time buyers’ housing.
|The dual use of the site was specifically considered during final consideration of the Local Plan for presentation to Tynwald and the owner did not object to the zoning or policies of the Plan.
|Paragraph 5.7 of the written statement to the Plan states, `An area bounded by Farrant’s Way and Scarlett Road is suitable for residential development.’ Paragraph 5.8 under Policy the Plan goes on to say `It is considered that the site bounded by Farrant’s Way and Scarlett Road should be developed for residential use allied to car parking’.
|It is clear that the term, `allied to car parking’ means public car parking. Section 7 of the Plan also makes clear that the term car parking in the context of the Local Plan refers to public car parking. The application makes no provision for public car parking on the site and is therefore contrary to the policies and provisions of the Castletown Local Plan 1991.
|With regard to the revision of the Castletown Local Plan – ‘Issues and Options’ document representations have been made that the site is suitable for residential development together with some public car parking.
|There is no guarantee that the land south of Scarlett Road will be developed for car parking and even if it is there is no long term guarantee that it will be maintained as a car park for public use. The owner of the land is also the owner of the application site and he has recently again refused to sell the land to the government for use as a public car park.
|To demonstrate that the site is capable of satisfactory development to meet the parking needs of Castletown and the housing needs of first time buyers Castletown Heritage submitted an outline application in November 2000. The proposal was for 21 two?storey dwellings and a public car park. This application was approved and has gone to the review stage.
|The design of the proposed development is not in keeping with the architecture of Castletown. The Georgian, Victorian and more recent development in Castletown is a mixture of stone and render. A large block of harsh modern brickwork would greatly disturb this effect and the proposed windows of aluminium or plastic would not be in keeping with the traditional sash windows.
|The site is very prominent, on a main route into the town and a bus route. It is impossible to comment fully on the details of the design due to the lack of detail submitted, but the reference to features from other buildings is risible. The design and materials are not in keeping with the traditional appearance of the town and the terraces fronting Farrant’s Way and Scarlett Road do not relate to other buildings in either road. The effect of the proposal would be of 2 terraces meeting at a corner where the terraces have been amputated leaving only stumps.
|The height, scale and massing of the proposed development are totally unsympathetic to buildings in the immediate surrounding area. Development south west of Farrant’s Way is predominantly one or two storeys high. The 3 and 4 storey development proposed would be totally out of keeping with this area. While the buildings on the opposite side of the road are largely 3 storey, they front Arbory Street and are some distance from the site. Outbuildings facing Farrant’s Way are generally low. The effect of the proposal would be a tall building towering over neighbouring development.
|Furthermore, the building would be higher than the Civic Centre on the opposite side of Farrant’s Way. Therefore it would not add a focal point to the Civic Centre, but would detract from this important public building within Castletown town centre.
|There is no adequate provision for childrens’ play or amenity space or private areas for refuse storage and clothes drying. The narrow strips of green between the main building and the road and also those between the building and the car parking spaces give the proposed development an unnaturally cramped appearance.
|The proposal makes no attempt to break up the car parking into a domestic scale. The large area of car parking at the rear is unattractive and could attract vandalism.
|In Blocks F&G in particular, some rooms seem to be of an inadequate size. Facilities for the disabled are lacking and no central aerials are shown which could lead to a plethora of aerials.
|Paragraph 6.26 of the Island Wide issues document ? consultation draft sets out criteria for affordable housing, which do not appear to be met. Paragraph 6.27 refers to the need to control over intensive development in housing areas. Over intensive development can lead to a built environment, which is lacking in quality of life and creates oppressive living conditions. Such situations may occur where higher densities are sought at the expense of adequate open space and separation of buildings to traffic and servicing issues.
|The proposed development would contravene these strategic plan issues and create an environment, which the Strategic Plan will specifically seek to avoid.
|The proposed development provides only one vehicular access from Farrant’s Way, a principal through route. While this might be logical for a town centre car park or to avoid visitors entering a residential area unnecessarily, it is not logical for a solely residential development to have a single access onto a through route.
|The proposed development would result in an over intensive use of the site out of keeping with neighbouring one and two storey dwellings on this side of Farrant’s Way, harmful to the appearance of the area and the amenity of neighbouring residents. The proposed development would result in the loss of the only possible site in central Castletown for an adequate public car park. It would prejudice the emerging Local Plan and any study of the need for and provision of affordable housing, traffic management and car parking and it should not be permitted.
|OBJECTIONS IN ADDITION TO THE ABOVE
|A number of objectors object to the procedure adopted for the application when DOLGE has interest in only 15 of the units out of a total of 80.
|Castletown Town Commissioners while not objecting to the proposed development as a whole, have strong concerns regarding the height of the gable wall, its close proximity to 1 Kissack Road and the impact the proposal would have on the outlook and natural light to that dwelling.
|Other objections raised include the effect of the proposed development on:
|the appearance of the area.
|the loss of amenity to nearby residents in Scarlett Close, Kissack Road and Farrant’s Way, in terms of outlook, privacy loss of sunlight and natural lighting.
|increased traffic congestion on Farrant’s Way.
|inadequate access for service and emergency vehicles.
|there are other areas of undeveloped land in Castletown zoned for predominantly residential use that could accommodate the town’s housing requirements.
|encroachment of building lines in Scarlett Road and Farrant’s Way.
|the extant planning approval for an office building (PA/94/1482) limits the height of that building to 3 floors.
|Objections by Mr and Mrs P Kinley of 1 Kissack Road and Mr and Mrs P S Gale of 3 Kissack Road.
|The general case applied. In addition the height mass and close proximity of the building would be seriously harmful to the outlook from habitable rooms at the rear of their bungalows and others in Kissack Road. The building would also cause overshadowing and loss of sunlight and daylight to the dwellings and their gardens.
|Objection by Mr A Metcalfe of 17 Scarlett Close.
|The general case applied. The proposed building would cast long shadows, which would reduce sunlight in the gardens of dwellings in Scarlett Close, particularly during the spring and autumn.
|The proposed development would result in noise, disturbance and inconvenience to the occupants of houses in Scarlett Close during construction. It would also increase difficulties of access and in particular make it difficult for service, refuse and emergency vehicles to access 12 to 17 Scarlett Close.
|A list of draft conditions was submitted (Document 18). In the event of approval being granted I consider all these conditions to be reasonable and necessary. In addition I consider a condition requiring the Department’s approval of details and samples of materials prior to commencement of the works should be imposed.
|From my inspection of the site and its surroundings and consideration of all the submissions and representations made it seems to me that the decision in this case will rest upon the effect of the proposed development on:
|the character and appearance of this part of Castletown.
|the provision of car parking for the town centre.
|the residential amenities of neighbouring residents, particularly those in Kissack Road and Scarlett Close.
|There is no dispute that there is a need for housing in Castletown and housing for first time buyers in particular. There is also no dispute that the site is suitable for housing.
|However, Farrant’s Way clearly forms the boundary between the historical older part of Castletown and the Castletown Conservation Area and the more recent residential area to the south. Development on the north side of Farrant’s Way within the town centre comprises largely 3 storey buildings, many with back additions which reduce in height and are generally set well back and separated from the road by back yards or gardens. South of the road the area comprises mainly one and two storey housing again set well back and separated from the road by gardens. As a result the road has an air of space on both sides.
|In my view the proposed 3&4 storey apartment blocks in close proximity to the road would be seriously out of character with neighbouring residential development south of Farrant’s Way and due to their height and siting close to the road, seriously harmful to the characteristic openness of the road. I also consider that the proposed building would dominate rather than complement the Town Hall and Library, which are buildings of a relatively modest scale and design.
|There is some dispute as to the meaning of Policy 5.8 of the adopted Local Plan, which states, `the site should be developed for residential use allied to car parking ….’. In view of the evidence presented I am inclined to accept the explanation that it means public car parking in connection with town centre uses.
|Whether or not this is correct it is clear that the proposed development would provide no public car parking. While there is no guarantee that the existing informal parking arrangement would continue, there can be no doubt that the proposed development would result in the loss of a well used car parking facility of considerable importance to the town centre.
|I acknowledge that the loss of this car parking may be ameliorated to some extent by development of another area on the opposite side of Scarlett Road, for which planning approval has been granted. However that development does not form part of this proposal and there can be no certainty that it will serve the same purpose or indeed proceed to completion.
|I turn now to the effect of the proposed development on the residential amenities of neighbouring residents. The lack of windows above ground level in the flank wall of the apartment block closest to Kissack Road would avoid any serious loss of privacy by overlooking. However, despite the wall treatment, due to its height and scale and particularly its proximity to the neighbouring dwellings I am firmly of the opinion that the flank wall would present a seriously overbearing and dominating appearance to the bungalows fronting Kissack Road and Nos.1 & 2 in particular. Furthermore it would cause a degree of overshadowing to parts of the dwelling and garden of No. l Kissack Road.
|I also think it likely that there would be some overshadowing of the garden of No. 17 Scarlett Close.
|The sloping vehicular access to the lower car parking level is close to the rear boundary of dwellings fronting Kissack Road and the upper level car park is very close to the rear boundaries of Nos. 14 to 17 Scarlett Close and the side boundary of 12 Scarlett Close. I consider that car parking on this scale so close to the boundaries of neighbouring dwellings would be likely to cause noise and disturbance significantly detrimental to the residential amenity of the occupants of these dwellings.
|In view of the above I conclude that the proposed development does not respect the amenities of existing dwellings bordering the site and it is therefore contrary to the provisions and policies of the emerging Local Plan.
|I have taken full account of the need for housing and for first time buyers’ housing in Castletown and in the Isle of Man as a whole. Nevertheless, I am of the firm opinion that this does not outweigh the severe disadvantages of this proposal, referred to above.
|In summary I consider that the proposed development would be seriously detrimental to the character and appearance of this part of Castletown. It would result in the loss of an informal car parking facility and make no provision for public car parking and it would be detrimental to the residential amenities of neighbouring residents to an unacceptable degree. In my opinion the proposed development represents a substantial over development of the site, which should not be permitted.
|For the reasons given above and having regard to all the other matters raised, I conclude that the application should be refused.
|I recommend that the application be refused.
|J Trevor Graham