Planning Fee

4 August: Commission to move against 20 euro planning objection fee

FIE has learned that the case against Ireland for imposing a 'participation fee' in the planning process is to proceed to the European Court of Justice.

The case, brought on foot of complaints by FIE on behalf of more than 60 community and environmental groups, alleges that Ireland has failed to make adequate provision to foster and encourage public participation in the environmental impact assessment process and in fact has actively discouraged such public participation by requiring the payment of a fee, which is contrary to the scheme and purpose of the Directive.

The EU legal move parallels FIE own's legal challenge in the Irish Courts, launched earlier this year.

See our website section on this 4 year battle to remove a fee that has resulted in a drop of 50% in comments by the public on proposed developments since its introduction in 2002.

Planning Fee Section
4 August: Commission to move against 20 euro planning objection fee

FIE has learned that the case against Ireland for imposing a 'participation fee' in the planning process is to proceed to the European Court of Justice.

The case, brought on foot of complaints by FIE on behalf of more than 60 community and environmental groups, alleges that Ireland has failed to make adequate provision to foster and encourage public participation in the environmental impact assessment process and in fact has actively discouraged such public participation by requiring the payment of a fee, which is contrary to the scheme and purpose of the Directive.

The EU legal move parallels FIE own's legal challenge in the Irish Courts, launched earlier this year.

See our website section on this 4 year battle to remove a fee that has resulted in a drop of 50% in comments by the public on proposed developments since its introduction in 2002.

Planning Fee Section
Friends of the Irish Environment have issued proceedings against the Minister for the Environment and the Attorney General seeking a declaration from the Courts that the requirement for the €20 fee required to comment on a planning application is 'null and void' for projects falling under the Environmental Impact Assessment Directive.

FIE's campaign against the fee began in 1999 when FIE organised a a complaint to the EU about the proposed fee on behalf of more than 60 community and environmental groups.

The European Commission issued a Reasoned Opinion in January 2002, finding the 'participation fee' infringed the EIA Directive.

A Reasoned Opinion is the last stage before the Commission brings a case before the European Court of Justice. Ireland implemented the fee nonetheless. [Read the Taoiseach's garbled response]

Read the submissions to the Minister for the Environment at the time of the introduction of the planning fee.

Fourteen local authorities, including the General Council of County Councils, passed motions to request that the fee would not be implemented. These motions highlighted the poorer decisions that would result as 'members of the public had consistently supplied these authorities with information that was useful and relevant'.

While the Local Authorities do not keep records of the number of objections before the fee was introduced, some have suggested privately that the fee has resulted in a decrease of more than 50% of the objections received. PRESS RELEASE
Friends of the Irish Environment have issued proceedings against the Minister for the Environment and the Attorney General seeking a declaration from the Courts that the requirement for the €20 fee required to comment on a planning application is 'null and void' for projects falling under the Environmental Impact Assessment Directive.

FIE's campaign against the fee began in 1999 when FIE organised a a complaint to the EU about the proposed fee on behalf of more than 60 community and environmental groups.

The European Commission issued a Reasoned Opinion in January 2002, finding the 'participation fee' infringed the EIA Directive.

A Reasoned Opinion is the last stage before the Commission brings a case before the European Court of Justice. Ireland implemented the fee nonetheless. [Read the Taoiseach's garbled response]

Read the submissions to the Minister for the Environment at the time of the introduction of the planning fee.

Fourteen local authorities, including the General Council of County Councils, passed motions to request that the fee would not be implemented. These motions highlighted the poorer decisions that would result as 'members of the public had consistently supplied these authorities with information that was useful and relevant'.

While the Local Authorities do not keep records of the number of objections before the fee was introduced, some have suggested privately that the fee has resulted in a decrease of more than 50% of the objections received. PRESS RELEASE
These are the original signatures to the Planning Fee Campaign at the Press Conference in Wednesday 9th February, 1999.

Note our Press Release that day stated:

It has been suggested that the proposals are unconstitutional but the attitude of the Irish Courts to those individuals who take environmental cases in the public interest gives us little hope that the matter can be resolved effectively within Ireland."

1. An Taisce
2. Arklow Action Group
3. Ballynagran / Coolbeg Action Group
4. Belclare Park and Terrace Residents and Tenants Association
5. Belgrove Residents Association
6. Blessington Heritage Trust
7. Bluestack Environmental Group
8. Braade/Carrigfin Residents Group
9. Brittas Bay Community Group
10. Coastwatch Europe
11. Commogue Marsh Protection Group
12. Cod's Head Preservation Society
13. Concerned Residents of Ardgehane/Ballinglanna
14. Coolea Ecology Group
15. Cork Environmental Alliance
16. Donabate Parish Council
17. Donegal Environmental Alliance
18. Dulra Magazine
19. Earthwatch
20. European Youth for Action
21. Foyle Basin Council
22. Friends of the Irish Environment
23. Friends of the Curragh Environment
24. Genetic Concern
25. Glasnevin Avenue Residents Association
26. Greystones Protection and Development Association
27. Hermitage and District Residents Association
28. Inistioge Conservation Society
29. Irish Doctors for the Environment
30. Irish Wildlife Trust
31. Just Forests
32. Keep Ireland Open
33. Killarney Nature Conservation Group
34. Kilcoursey Residents Association
35. Killincarrig Community Association
36. Kilmaley Anti-Dump Action Group
37. Knockmealdown Protection Committee
38. Lancefort Ltd.
39. Leinster Road Residents Association
40. London Irish Green Party
41. Lorretto Grange Residents Association
42. Mount Argus Road/Grove Residents Association
43. Moville/Greencastle Residents Group
44. Native Woodland Trust
45. Newcastle Residents Association
46. Newgarden Residents Association
47. Newtown Area Action Development Group
48. Novara Sydmonton Residents Association
49. Poddle Area Resident's Association
50. Rathgar Residents Association
51. Ringaskiddy and District Residents Association
52. Rural Environmental Awareness Protection Group
53. Sandcove Seafront Residents Association
54. Sandford Road Residents Association
55. Save Glending Group
56. Stradbelly Environmental Protection Group
57. Strand Street Residents Group
58. Strawberry Beds Residents Association
59. Union Hall Residents Committee
60. VOICE
61. Waste Action Group
62. Wicklow Environmental Solutions Trust
63. Wicklow Planning Alliance
64. Willow Cedar Action Group
65. Woodbrook and Stratten Pines Residents Association
66. Woodquay & District Residents
We reprint this extract from the Dail and invite readers to consider for themselves whether the Commission's reasoned opinion contains a statement about the legality of the situation.
Dail Report, 21 February, 2002

Mr. Cuffe: On the same matter, now that the European Commission has ruled that the €20 planning fee is illegal, will the Minister for the Environment and Local Government be refunding those who paid the fee? Will he introduce regulations to ensure that members of the public will not have to pay this draconian fee in order to participate in the planning process?

The Taoiseach: I understand that the European Commission has given a reasoned opinion but I do not think it has made any statement about the
legality of the situation. Obviously, the Minister will now have to examine the judgment.
SUMMARY OF SUBMISSIONS
OPPOSED TO THE IRISH PLANNING FEE
obtained under Freedom of Information
LOCAL AUTHORITIES

14 elected Local Authorities, including the General Council of County Councils, passed motions to request that this fee not be implemented, highlighting:

¬? the poorer decisions that would result as members of the public had consistently supplied them with information that was useful and relevant
¬? the difficulty of public representatives fulfilling their own role in making representations on behalf of their constituents [This is particularly true as functional illiteracy is high in Ireland]
¬? an inevitable lessening of public involvement in decision making (with consequent lose of commitment)
¬? a lose transparency and therefore a decrease in public confidence
¬? the task of dealing with objections or submissions is not considered onerous anyway
¬? the planning fee at IR£ 47 is totally inadequate and results in a net cost to the State of IR£ 10m while in Northern Ireland the fee is UK£ 375
¬? the cost of the planning system should be met by those availing of the service


General Council of County Councils
Fees for planning applications: Section 34 & 222
(a) The General Council would have difficulty with the prospect of a fee for making observations on, or objections to, planning applications.
There is fIR£tly a problem on the level of principle. It is the applicant, not the objector, who is the one who initiated the application. It is the applicant who is changing the status quo. A householder, for example, is quite happily living in his or her house when an applicant applies to build an intensive pig unit in the field across the road. Naturally the householder is concerned and wants to make an observation to the planning authority on this. Why should the householder then be forced into expense, no matter how nominal, because of a third party's unsolicited proposals?

(b) Local authority elected members, and indeed Oireachtas members, are called on to make representations on planning applications, be they supportive or in objection to the applications. This activity has become one of the biggest facet of Councilor's workloads. While the higher theory of the planning system might be that Councilor's have their say at the Development Plan stage, the fact is that individuals, resident's associations etc expect councilors to make representations on their behalf. There could be no question of councilors having to pay a fee for such an integral part of their representative duty.

It is accepted that the charging of a fee would help contribute to the increasing administrative costs on Councils in dealing with planning files. However to impose a charge on a person's right as distinct from a charge for service is neither logical nor fair."

Ardee Town Commissioners
"The members objected to the proposal to introduce a fee for persons who wished to lodge planning objections to the Local Authority. The members feel that any fee would discourage less well off people from lodging valid objections."

Offaly County Council
"That we the Council call on the Minister for the Environment and Local Government to amend the Planning Bill 1999 to remove the fee payable by members of the public wishing to comment on planning applications."

Killarney Urban District Council
"I wish to inform you that at the November meeting of Killarney Urban District Council it was resolved that "in the interests of maximizing public involvement, ensuring transparency and thereby increasing public confidence in the planning system, this Council rejects the proposed introduction of a fee to accompany planning submissions and the proposed bar on submitting an appeal to An Bord Pleanala if a prior acceptable submission had not been received by the relevant local authority, and calls on the Minister for the Environment and Local Government to withdraw this unjustified attack on the democratic rights of citizens."

Sligo County Council
"That in the interest of maximizing public involvement, ensuring transparency, and thereby increasing public confidence in the planning process, this Council rejects the proposed introduction of fees to accompany planning submissions and the proposed bar on submitting an appeal to An Bord Pleanala, if a prior acceptable submssion has not been received by the relevant planning authority, and call on the Minister for the Environment and Local Government to withdraw this unjustified attack on the democratic rights of citizens."

Trim Urban District Council
"The members are particularly concerned at the intention as part of planning regulations, to introduce fees for making submissions on planning applications and have asked that this element of the streamlining of the planning system be re-examined."

Galway County Council
"It was noted that under Section 222 of the Bill the Minister may require fees to be charged for the making of submissions or observations on planning applications. The members felt that councilors should be exempt from any such provision and that no fee should apply to any councilor making a submission or observation on a planning application."

Cork Corporation
"That this Council expresses its outright condemnation of the proposals included in the current Bill before the Houses of the Oireachtas, that members of the public and/or elected public representatives will be required to pay a fee to relevant local authorities when making observations, objecting to, or expressing opposition to planning applications made to local authorities. That the imposition of such a fee places an unfair onus on people affected by planning applications and represents an attack on the democratic right to protest."

Dun Laoghaire, Rathdown County Council
"That this Council request the Minister for the Environment and Local Government to eliminate the proposed fee to comment on planning applications, as proposed in the new Planning and Development Bill.

That this Council requests the Minister for the Environment Mr. Dempsey to drop the proposal to introduce a charge for planning objections and observations at Planning Authority level."


Dublin Corporation
Introduction of Fees for Objectors
"Members were in favor of streamlining proposals and the elimination insofar as it was possible of mischievous objections. However, they expressed their concern to the widespread charging of fees on submissions especially in so far as they related to submissions by residents Associations, occupiers or neighbors of adjoining properties, bodies charged with the restoration or preservation of the built environment and other such bodies that were above board. As this proposal is linked with the right to make an appeal to An Bord Pleanala, concern was expressed that a bone fide objector, e.g. a next door neighbor might be away when the application was being dealt with by the planning authority and would thus be prevented from lodging an appeal with An Bord Pleanala.


Killarney Urban District Council
"At the November meeting of the Kilarney Urban District Council it was resolved that "in the interests of maximizing public involvement, ensuring transparency and thereby increasing Public Confidence, in the planning system, this council rejects the proposed introduction of a fee to accompany panning submissions and the proposed bar on submitting an appeal to An Bord Pleanala, if a prior acceptable submission had not been received by the relevant local authority, and calls on the Minister for the Environment and Local Government to withdraw this unjustified attack on the democratic rights of citizens".

Newbridge Town Commissioners, Co. Kildare
"The Commissioners feel that the right to make a submission on a planning application is an important one and they have resolved to request that this would continue to be free of charge."

Leixip Town Commissioners, Leixlip, Co. Kildare
"I am asked by the Town Commissioners, on foot of a resolution adopted by them, to inform you that they object to the proposal to introduce a charge for making submissions on planning applications which is included in the new Planning Bill." Mary Foley, Town Clerk

Offaly County Council
"That we call on the Minister for the Environment and Local Government to amend the Planning Bill 1999 to remove the fee payable by members of the public wishing to comment on planning applications."

Monahan County Council
"The levying a small charge for making a submission on planning applications will discourage frivolous objections. However submissions from locals do highlight issues which the planning authority may not be aware of in a locality and presently, the task of dealing with objections or submissions is not considered onerous.
A proposed levy with a nominal charge (£5, £10 or £20) would not raise income levels significantly (one joint or shared submission could be presented per application) and will place another unnecessary administrative burden on planning authorities.
My personal preference would be for a 100% increase in the application fees for non-commercial planning permissions. I see no reason why the cost of providing a planning service in a rural planning authority such as Monaghan County Council should not be met by those availing of the service.
In 1999 Monaghan County Council will expend £246,302 directly on Land Use Planning. The receipts from this source will be £126,700. In addition overheads of £115,000 in respect of Central Services must be added to the expenditure figure, resulting in a net charge onto the rates of £234,602. The total estimated cost of the planning services provided by the 29 County Councils in 1999 is £19.44m (excluding Central Service charges). The estimated income is £9.95m. In Northern Ireland the planning application fee for full permission for a single domestic dwelling is £375. Here it is £47!

If the planning service "paid for itself", local authority managers would be more inclined to allocate the extra resources that are required to release the bottlenecks in the system. Presently, managers have to balance demands for extra resources for the planning service with Iimited increases in the Local Government Fund Grant."



INSTITUTIONS

The institutions were concerned that the proposals were a "seriously retrograde step", citing in particular:
¬? that giving statutory recognition to such submissions merely reflects current practice in any event
¬? the fee is not in line with one of the key principals of sustainable development, that of public participation
¬? the submission of observations from third parties provides an invaluable service to planning authorities
¬? the fee would prevent many of those most vulnerable to poor planning from making submissions on developments that adversely affect them.
¬? Community and amenity groups will not be able to take a systematic approach to planning in their areas.


Irish Planning Institute and Royal Town Planning Institute

"The Institutes are disappointed that our suggested recommendations were not taken on board in relation to aspects of this Bill.

"We remain convinced that the imposition of a fee to make a submission under Section 34 (3) (b) on a planning application to a planning authority is a seriously retrograde step. Planning authorities provide a public service which is paid for partly by the users of that service, i.e. the applicants, but also largely by the public. It is considered to be a public service element of the functions of planning authorities that interested parties in individual planning applications can make comment. Giving statutory recognition to such submissions merely reflects current practice in any event, and this statutory recognition should not be at the cost of a fee. If it is considered that administrative costs are to be addressed, then such costs should be covered by the application fees since all the issues surrounding individual planning applications are effectively raised by the applicants themselves in making an application."

The Heritage Council,
Re: Section 33(2)(c)
"The introduction of a fee which would be payable by third parties to make submissions or observations on applications for planning permissions is not in line with one of the key principals of sustainable development, that of public participation. Given the current lack of specialized expertise amongst planning authorities in relation to a number of areas of sustainable development, the submission of observations from third parties provides an invaluable service to planning authorities in their attempts to assess applications in a comprehensive manner. This section should contain an explicit recognition of the value of third party involvement in the planning process."

The Arts Council
"Subsection 2(c) of Section 33 enables persons to make submissions in respect of applications on "payment of the prescribed fee". Given the status of the prescribed bodies in the planning process and to encourage the planning authorities to utilize their expertise by seeking out their submissions on certain applications, a further paragraph should be included along the following lines:
Enabling prescribed bodies to make submissions and observations with respect to applications forwarded to them by the relevant authority without payment of prescribed fee."

An Taisce, The National Trust for Ireland
"One provision in the Bill (33(2)(c) is extraordinary, and unacceptable in a modern democracy. The imposition of an entirely new fee that has been mooted at IR£ 20 to lodge an objection is an affront. In our experience it would prevent many of those most vulnerable to poor planning from making submissions on developments that adversely affect them. Other community and amenity groups might not be able to take a systematic approach to planning in their areas. We note that, on a recent visit to Dublin, an OECD representative commented on this matter "What? Next they will be charging to vote!"

Charges for submissions was previously tried in 1984 for financial reasons but was abandoned within months as it did not make a positive contribution to the operation of local authorities."



RESIDENTS GROUPS

A number of residents groups made representations outside of the 70 that were represented by Friends of the Irish Environment. These were largely Dublin based community groups who would have been more aware of the proposed fee than many rural groups. They made the following points:

¬? They all would find it extremely difficult to continue their work if this charge is imposed
¬? They already have to dip into their personal pockets when they wish to be a party to an appeal and so the fee is unjust and unfair
¬? The charge was tried in the past and was rapidly dropped


Selected comments include:

Hillwatch, Sutton, Dublin 13
"We are strongly opposed to the proposed IR£ 20 charge to third parties, including groups such as ours. As a voluntary organization, making several such submissions a month, we would find it extremely difficult to continue our work if this charge is imposed. We already have to dip into our personal pockets when we wish to be a party to an appeal. We believe the planning system will not be served by this proposal. Valuble information will not be available to the planners. Apparently in the past a IR£ 10 charge such as this was imposed and I am reliably informed it was dropped. As a past Chief Architect said the planners were as a result without necessary information to come to reasoned opinion."


Infirmary Road and District Community and Environmental Group
"Dear Minister;
I refer you to a recent telephone call by a member of the above group with an official on your staff in connection with the above matter. We strongly object to such a proposed levy. This is a small area with less than 200 houses, built in the late 1800's and situated in the center of the largest tourist area in Dublin overlooking the Phoenix Park. The area is also situated in the Taoiseach's own constituency.

We have many many problems in the area with landlords and developers. We work very hard to keep the area environmentally friendly. We won fIR£t prize overall in the Dublin Corporation Tidy Districts Competition 1999, and are nominated to go forward to represent the residential category in the Guinness Living Dublin Awards in November.

In the past number of months we found it necessary to lodge an objection to two planning applications, where we felt that the buildings proposed were not in keeping with the existing houses in the area. As we are a voluntary organization we would have had to pay any levy out of our own resources.

We are of the opinion that the proposed levy is unjust and very unfair, and we ask you not to implement same."


PUBLIC REPRESENTATIVES

TDs acted on behalf of constituents and in particular of residents groups. While some were neutral in performing this role, others, even in the Government Party, thoroughly agreed with the concerns of their constituents. They suggested:

¬? the fee was taking away from the citizen his right to object
¬? the Local Authority Registrar of Residents Associations should have a limit put on how much they would be required to spend on submitting objections
¬? Residents Associations should in fact receive professional help and assistance in preparing their cases
¬? there are still high levels of households in receipt of welfare payments so that even a small fee might present difficulties
¬? any fee collected would be of little value to a local authority and could be a disincentive to people who may have important views to express
¬? the prolific pace of development require multiple submissions


Bertie Ahern, Taoiseach
I am writing to you on behalf of Ms Eileen Lynch regarding her concern that there will be a charge of IR£ 20 for all planning objects lodged with Dublin Corporation. Ms Lynch feels that this is taking away the right of a citizen to object to any particular planning application and gives the developer the advantage. I would be grateful if you would take on board Ms Lynch's views."

Eoin Ryan, TD, Dublin 4

I have received a number of letters from residents Associations in my constituency about the recent planning Bill.

As you are aware, in some areas there is a considerable amount of development taking place and Residents Associations are rightly vigilant on these applications. Sometimes, they are making observations and objecting to some small matters regarding these developments and other times, they are objecting completely to the development. The point they are making is that there will be a serious increase in their spending if they had to put IR£ 20 in
with every single residents association submission. They are asking that the Local Authority Registrar of Residents Associations would have a limit put on how much they would have to spend on submitting objections."

Nutley Residents Association
"As the local Dail representative you will be all too well aware of the excessive development in the Dublin 4 area and the recent prolific development of hotels and guesthouses which have added considerably to the traffic and against the residents wishes. We expect you to oppose the proposal to charge for making objections to planning applications as we see our area under siege and all green space need not be built upon. We would be prepared to register with the local authority annually as an approved entity that could oppose development for the common good and channel all objections through our license.

"We are also concerned that it is so expensive on our funds to oppose professional institutions such as the St. Vincent's Hospital, RTE & Tesco when they plan developments, the fIR£t two with taxpayers money. Would the Deputy consider recommending that approved Resident's Associations could have access to assistance and help to make their point properly and professionally?"


Liam Lawlor, TD
"You will appreciate I am in receipt of representations from individuals and groups residing in areas where there are still high levels of households in receipt of welfare payments so that even a small fee might present difficulties."


Cllr. Tommy Broughton, T.D.
"Please find enclosed submission on the Planning Bill for the Sutton Park and Lawns Resident's Association. I thoroughly agree with all the concerns they raise and would welcome your comment."

Cllr. Brian McKenna
"I would propose that in relation to Section 33 (2) (c) that the words 'the payment of a prescribed fee' be deleted in relation to observations or comments concerning a planning application. The number of observations, I would contend, are relatively small in terms of the total number of applications submitted and as such any fee collected would, in my opinion, be of little value to a local authority and could be a disincentive to people who may have important views to express.'


NON GOVERNMENTAL ORGANISATIONS

Ireland's major non-governmental organizations were all signatures to the complaint made by Friends of the Irish Environment. Other submissions highlighted:

¬? these groups were not objecting on a once-off basis but faced significant accumulated costs
¬? it would financially penalize those who were tryingto encourage our authorities to achieve better architectural standards
¬? OECD performance evaluator Henri Smets, told Irish NGOs that "It is not simply a financial matter, it is a matter of principle."
¬? the fee is out of scale with Irish NGO budgets, where IR£ 30 is the amount that would be collected from donations at a well attended branch meeting



Barra Salmon Angling Association, County Mayo
"The proposed fee may not be excessive in a once-off situation. However, our group and I assume many others around the country have occasion to lodge objections to various applications on a regular basis. Our only reason for doing so is to try and protect and preserve our unique environment in the West.

The pressure, especially in recent years and the experience in all kinds of developments is making it more and more difficult to preserve what we have, either from direct pollution in waters or visual pollution of our landscapes. Objections, appeal to An Bord Pleanala, and Oral Hearings are foir a voluntary body with no outside funding time consuming and financially draining.

Your proposal if implemented will add to that burden and will result in restrictions on the number of objections we would normally make."


Irish Georgian Society
A detailed commentary on this Bill follows, but the Society would like to emphasize a number of provisions that we hope you will change before this Bill is enacted.

Section 33 (2) (b) is of particular concern, in that charging people to make submissions to Local Planning authorities will discourage public participation, and in regard to conservation, will be adverse as local historical and archaeological societies, as well as bodies like the Irish Georgian Society, will be penalized financially for trying to encourage the Authorities, and others, to respect our architectural heritage."


The Irish Wildlife Trust
"The proposal (section 222) to charge individuals and organizations a fee to comment on planning applications is unjust and should be removed. It is stated that this fee would "not be such as to deter people who have genuine concerns from making submissions to the planning authority".(Feargal O Coigligh, Streamlining the Planning Process). However, the IWT believes that the fee may act as an inhibitor. It would certainly affect the work of the NGOs which is already constrained by lack of funding. In many instances, comments at this stage may help planners identify an unknown problem with the proposed development e.g. the site floods in the winter. The OECD stated at the Environmental Performance Review of Ireland on Friday 8 October, 1999 that the right to comment / object was akin to the right to vote. Henri Smets, OECD said "It is not simply a financial matter, it is a matter of principle." The IWT calls for the proposal to introduce charges to be dropped."


BirdWatch Ireland (South Dublin Branch)
"We would urge you not to impose a charge for submissions on planning applications, as this will waste our already scant resources without changing the number of such submissions. IR£ 30 is the amount that would be collected from donations at a well attended branch meeting, or a good fee for a conservation lecture to an outside organization (both of which require several hours of preparation and no little effort) and is an unfair imposition when no benefit is derived thereby. Indeed, we would feel that it would instead benefit your Department to encourage public participation in the planning process, as this would make citizens take 'ownership' of their areas and encourage responsible use."

COMHAR, The National Sustainable Development Partnership
Participatory Democracy
Comhar is opposed to the principle of charging persons to make submissions and recommend that Section 33(2)(c) should be omitted.

Comhar feels that the implementation of a prescribed fee for making submissions:
¬? Would be contrary to the principal of participatory democracy
¬? Would be costly for local authorities administratively unless a higher fee was charged
¬? Could lead to the exclusion of comments made in the interest of the public good.

ENDS