Local Planning Policy In Practice - Fiscal, Public and Economic Impacts.
Dear Haringey Borough Council,
This request is made under the Freedom of Information Act 2000, and in accordance with paragraph 1.4.2 of Haringey’s Authority Monitoring Report (AMR) 2016/17 (helping communities to engage in the planning process, and to understand the impact of planning policy and practice on development and growth across the London Borough of Haringey).
In the spirit of openness and the interests of transparency, your response may be made publicly available.
FOR THE PERIOD 1ST APRIL 2016 TO 31ST MARCH 2017 (The AMR period) please provide the following information, under the Open Government Licence, in electronic form and reusable format:
1) Schedule of documents relating to departmental spending data, and datasets for: a) the handling of planning applications. b) the planning enforcement and appeals service.
2) What was the recorded number of officers employed and/or contracted by the Council, at any one time during the period, to handle: a) planning applications? b) planning enforcement & appeals?
3) Of the 144 Enforcement Notices issued during the period, please disclose how many are recorded to have resulted from: a) matters raised by officers (distinct from concerns raised directly by public complaints). b) anonymous complaints.
4) The number of Planning Enforcement Notices recorded during the period as: a) complied with, without recourse to appeal, including through the submission of retrospective planning applications. b) withdrawn. c) appealed. d) allowed by the Planning Inspectorate. e) resulted in prosecution by the Council, direct action or injunction.
5) The number, and if reasonably practicable, records, of Applications for costs lodged against the Council for unreasonable behaviour causing unnecessary or wasted expense, in: a) appeals of refusals. b) appeals of Enforcement Notices. c) number and records of costs applications pending a decision as at 31 March 2017.
6) The number of Costs Awards made Against the Council during the period, for unreasonable behaviour causing unnecessary or wasted expense, in relation to: a) appeals of refusals. b) appeals of Enforcement Notices. c) unreasonable behaviour concerning i) procedural matters, ii) substantive matters, iii) both procedural and substantive matters. d) records, including appeal reference numbers, of the Planning Inspectorate reasons for awarding costs against the Council.
7) The overall monetary value of compensation resulting from officers’ unreasonable behaviour: a) paid during the period. b) budgeted and yet to be paid, as at 31 March 2017?
8) To whom was the power delegated, to issue notices that were subsequently appealed, if to anyone in addition to the Acting Team Leader for Enforcement and Appeals?
9) Number of officer hours or days taken up defending cost applications against the Council, for alleged unreasonable behaviour causing unnecessary or wasted expense. If this information is not disaggregated in departmental spending data, and/or if extraction of this information is not quick and easy, please provide any readily available records showing a time estimate, monetary calculation, or evaluation of this fiscal cost as a percentage of the overall planning budget.
10) Please provide records of any scrutiny, quantitative and/or qualitative evaluation of the delay and financial impacts of officers’ unreasonable behaviour on the public interest, including individuals, businesses and the local economy. If such information is not readily available, please provide the file structure or list of files relating to the Council’s consideration of Strategic Policy SP17 “Delivering and Monitoring the Local Plan”. In relation to the information requested in this part of the request (paragraph 10), please include information covering the 3 years preceding the AMR period commencing 1 April 2016.
11) Records of any appraisal of proper governance of the planning and enforcement functions, including officers’ compliance with legislation, and adherence to planning policy, practice guidance and formal representations. Please include records of any measures taken by the Council to prevent or minimise unreasonable behaviour resulting in unnecessary or wasted expense (for appellants and the council), and/or to reduce the unnecessary imposition of damaging delays and financial burdens on applicants, businesses and the local economy.
12) Please provide the Index and Records of enforcement notices issued, or make the same reasonably accessible. The Council’s Online Enforcement Register linked to below, does not enable tracing entries by reference to the land to which enforcement notices relate. It appears not to fulfil the requirement of article 43 of the Development Management Procedure (DMP) Order. Searches using variables including address details, reference numbers and dates do not generate relevant results. http://www.planningservices.haringey.gov...
13) Information contained in the Council’s Online Enforcement Complaints Register, including dates and address details, is incorrect and incomplete. The AMR states that performance of the planning enforcement team is improving and has improved significantly (including 95% of “notifications of decisions within 8 weeks”). Please provide the information or access to the information on which this assessment is based, including details of Public Complaints received during the AMR period. https://eforms.secure.haringey.gov.uk/uf...
14) Records of the Council’s procedures for monitoring and dealing with conflicts of interest and/or undue influence (from within or outside the Council) being brought to bear on officers’ impartial and free decision making responsibilities.
15) Records of the council’s procedures for monitoring payments or the provision of other benefits (other than from Haringey Council) made or provided to planning officials while carrying out their planning and enforcement duties.
Yours faithfully,
G. Levy
Silver Bullet
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Dear Mr Levy
Freedom of Information / Environmental Information Regulations Request:
LBH/6944918
I acknowledge your request for information received on 02 January 2018.
This information request will be dealt with in accordance with the Freedom
of Information Act 2000 / Environmental Information Regulations and we
will send the response by 30 January 2018
Yours sincerely,
Feedback and Information Governance
Shared Service Centre | Central Team
Haringey Council
10th Floor, Alexandra House, 10 Station Road, Wood Green, London N22 7TR
facebook.com/haringeycouncil
This email and any files transmitted with it are confidential, may be
subject to legal privilege and are intended only for the person(s) or
organisation(s) to whom this email is addressed. Any unauthorised use,
retention, distribution, copying or disclosure is strictly prohibited. If
you have received this email in error, please notify the system
administrator at Haringey Council immediately and delete this e-mail from
your system. Although this e-mail and any attachments are believed to be
free of any virus or other defect which might affect any computer or
system into which they are received and opened, it is the responsibility
of the recipient to ensure they are virus free and no responsibility is
accepted for any loss or damage from receipt or use thereof. All
communications sent to or from external third party organisations may be
subject to recording and/or monitoring in accordance with relevant
legislation.
Dear Mr Levy,
Re: Freedom of Information Act Request ref: LBH/6944918
Thank you for your request for information received on 02 January 2018, in
which you asked for the following information:
“FOR THE PERIOD 1ST APRIL 2016 TO 31ST MARCH 2017 (The AMR period) please
provide the following information, under the Open Government Licence, in
electronic form and reusable format:
1) Schedule of documents relating to departmental spending data, and
datasets for: a) the handling of planning applications. b) the planning
enforcement and appeals service.
2) What was the recorded number of officers employed and/or contracted by
the Council, at any one time during the period, to handle: a) planning
applications? b) planning enforcement & appeals?
3) Of the 144 Enforcement Notices issued during the period, please
disclose how many are recorded to have resulted from: a) matters raised by
officers (distinct from concerns raised directly by public complaints). b)
anonymous complaints.
4) The number of Planning Enforcement Notices recorded during the period
as: a) complied with, without recourse to appeal, including through the
submission of retrospective planning applications. b) withdrawn. c)
appealed. d) allowed by the Planning Inspectorate. e) resulted in
prosecution by the Council, direct action or injunction.
5) The number, and if reasonably practicable, records, of Applications for
costs lodged against the Council for unreasonable behaviour causing
unnecessary or wasted expense, in: a) appeals of refusals. b) appeals of
Enforcement Notices. c) number and records of costs applications pending a
decision as at 31 March 2017.
6) The number of Costs Awards made Against the Council during the period,
for unreasonable behaviour causing unnecessary or wasted expense, in
relation to: a) appeals of refusals. b) appeals of Enforcement Notices. c)
unreasonable behaviour concerning i) procedural matters, ii) substantive
matters, iii) both procedural and substantive matters. d) records,
including appeal reference numbers, of the Planning Inspectorate reasons
for awarding costs against the Council.
7) The overall monetary value of compensation resulting from officers’
unreasonable behaviour: a) paid during the period. b) budgeted and yet to
be paid, as at 31 March 2017?
8) To whom was the power delegated, to issue notices that were
subsequently appealed, if to anyone in addition to the Acting Team Leader
for Enforcement and Appeals?
9) Number of officer hours or days taken up defending cost applications
against the Council, for alleged unreasonable behaviour causing
unnecessary or wasted expense. If this information is not disaggregated in
departmental spending data, and/or if extraction of this information is
not quick and easy, please provide any readily available records showing a
time estimate, monetary calculation, or evaluation of this fiscal cost as
a percentage of the overall planning budget.
10) Please provide records of any scrutiny, quantitative and/or
qualitative evaluation of the delay and financial impacts of officers’
unreasonable behaviour on the public interest, including individuals,
businesses and the local economy. If such information is not readily
available, please provide the file structure or list of files relating to
the Council’s consideration of Strategic Policy SP17 “Delivering and
Monitoring the Local Plan”. In relation to the information requested in
this part of the request (paragraph 10), please include information
covering the 3 years preceding the AMR period commencing 1 April 2016.
11) Records of any appraisal of proper governance of the planning and
enforcement functions, including officers’ compliance with legislation,
and adherence to planning policy, practice guidance and formal
representations. Please include records of any measures taken by the
Council to prevent or minimise unreasonable behaviour resulting in
unnecessary or wasted expense (for appellants and the council), and/or to
reduce the unnecessary imposition of damaging delays and financial burdens
on applicants, businesses and the local economy.
12) Please provide the Index and Records of enforcement notices issued, or
make the same reasonably accessible. The Council’s Online Enforcement
Register linked to below, does not enable tracing entries by reference to
the land to which enforcement notices relate. It appears not to fulfil the
requirement of article 43 of the Development Management Procedure (DMP)
Order. Searches using variables including address details, reference
numbers and dates do not generate relevant results.
[1]http://www.planningservices.haringey.gov...
13) Information contained in the Council’s Online Enforcement Complaints
Register, including dates and address details, is incorrect and
incomplete. The AMR states that performance of the planning enforcement
team is improving and has improved significantly (including 95% of
“notifications of decisions within 8 weeks”). Please provide the
information or access to the information on which this assessment is
based, including details of Public Complaints received during the AMR
period.
[2]https://eforms.secure.haringey.gov.uk/uf...
14) Records of the Council’s procedures for monitoring and dealing with
conflicts of interest and/or undue influence (from within or outside the
Council) being brought to bear on officers’ impartial and free decision
making responsibilities.
15) Records of the council’s procedures for monitoring payments or the
provision of other benefits (other than from Haringey Council) made or
provided to planning officials while carrying out their planning and
enforcement duties”.
My response is as follows.
Section 12 of the Freedom of Information Act allows public authorities to
refuse requests for information where the cost of dealing with them would
exceed the appropriate limit, which for local government is set at £450.
This represents the estimated cost of one person spending 18 hours in
determining whether the department holds the information, locating,
retrieving and extracting the information. In this case the Council
estimates that the work required to provide the information – for the most
part in terms of points 4, 5 and 6 – would total around 25 hours of staff
time, or £625. This would largely be attributed to the retrieving and
interrogation of planning enforcement files for the 144 cases that are
relevant to your request. Thus, we have estimated that it will cost more
than the ‘appropriate limit’ to consider your request and consequently the
Council is not obliged by the Freedom of Information Act to respond to
your request. We will not therefore be processing your request further.
Some of the information to which you refer can be accessed on the
Council’s website (your requests 12 and 13).
The Council does not record data relevant to your requests 9, 10 and 11,
other than notes of individual employee appraisals (in respect of request
11) however these appraisals are considered exempt under S41.
You may wish to amend your request in light of the above and submit a new
request. Or you could seek to receive the information upon payment of a
fee (£625).
If you are unhappy with how we have responded to your request you can ask
us to conduct an Internal Review. If so, please contact the Feedback and
Information Team as below. (Please note you should do this within two
months of receiving this response.)
Feedback and Information Team
10th Floor, Alexandra House
10 Station Road
London
N22 7TR
E [3][email address]
Yours sincerely,
Dean Hermitage | Head of Development Management
Planning, Regeneration and Development | Haringey Council
River Park House 225 High Road | London | N22 8HQ
Tel: 020 8489 4753 [mobile number]
[4]www.haringey.gov.uk
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free of any virus or other defect which might affect any computer or
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of the recipient to ensure they are virus free and no responsibility is
accepted for any loss or damage from receipt or use thereof. All
communications sent to or from external third party organisations may be
subject to recording and/or monitoring in accordance with relevant
legislation.
References
Visible links
1. http://www.planningservices.haringey.gov...
2. https://eforms.secure.haringey.gov.uk/uf...
3. mailto:[email address]
4. http://www.haringey.gov.uk/
http://www.haringey.gov.uk/
Dear Hermitage Dean,
Thank you for your response, which is fully addressed below. I trust this enables you to process the refined request, which does not require exempt information or time consuming data extraction:
REQUEST POINTS 1 and 2:
Please provide the information requested.
REQUEST POINT 3:
Please provide the disaggregation sought, unless this is as prohibitive as suggested in the council’s response, specifically in relation to points 4, 5 and 6 below.
REQUEST POINTS 4, 5 and 6:
Thank you for clarifying related considerations. Please exclude points 4, 5 and 6 and process the remainder of the request, which does not require detailed interrogation of notices.
REQUEST POINTS 7 and 8:
Please provide the information requested.
REQUEST POINT 9:
Thank you for confirming that Haringey council does not record its costs in defending officers’ unreasonable behaviour. Please exclude this element, in addition to points 4, 5 and 6.
REQUEST POINTS 10:
Since the council does not hold data concerning impacts of unreasonable behaviour on applicants or the local economy, please also exclude these elements of the request. However, please do include data (other than the data requested in point 7) about the impact of such behaviour on the council’s budget, for example, the cost of consequential delays to developments and resulting loss of income from council tax and business rates.
REQUEST POINT 11:
Exempt records are not requested - The council’s website and publications (for example, enforcement guide and enforcement charter) exclude policy provisions for reducing unreasonable behaviour and associated costs. Please provide the information requested, excluding individual employee appraisals.
REQUEST POINT 12:
The response suggests that (some of the) information can be found on the council’s website: The request acknowledges this and includes a link to the relevant web page. Access to an index or ability to trace notices, as required by the Development Management Procedure (DMP) Order, remains unavailable. Please provide access to the requested information.
REQUEST POINT 13:
The response suggests that (some of the) information can be accessed on the council’s website: As described in the request, the Online Enforcement Complaints Register does not allow finding or viewing planning enforcement complaints (as incorrectly stated elsewhere on the council’s website). Please reconsider point 13 and provide access to the data on which assessment of the performance of the planning enforcement team has been based.
REQUEST POINTS 14 and 15:
Please process as requested.
Thank you for your assistance with this request.
Yours sincerely,
Silver Bullet
Dear Mr Levy
Freedom of Information / Environmental Information Regulations Request:
LBH/6971018
I acknowledge your amended request for information received on 11 January
2018.
This information request will be dealt with in accordance with the Freedom
of Information Act 2000 / Environmental Information Regulations and we
will send the response by 08 February 2018
Yours sincerely,
Feedback and Information Governance
Shared Service Centre | Central Team
Haringey Council
10th Floor, Alexandra House, 10 Station Road, Wood Green, London N22 7TR
facebook.com/haringeycouncil
This email and any files transmitted with it are confidential, may be
subject to legal privilege and are intended only for the person(s) or
organisation(s) to whom this email is addressed. Any unauthorised use,
retention, distribution, copying or disclosure is strictly prohibited. If
you have received this email in error, please notify the system
administrator at Haringey Council immediately and delete this e-mail from
your system. Although this e-mail and any attachments are believed to be
free of any virus or other defect which might affect any computer or
system into which they are received and opened, it is the responsibility
of the recipient to ensure they are virus free and no responsibility is
accepted for any loss or damage from receipt or use thereof. All
communications sent to or from external third party organisations may be
subject to recording and/or monitoring in accordance with relevant
legislation.
Dear Haringey Borough Council,
In the interest of open and proper management of the planning function, please provide the information requested. An adequate response may be a small positive step towards mitigating the negative impact of certain practices:
Planning enforcement is intended to be remedial rather than punitive. Facts and solutions must be explored before using significant enforcement powers. In Haringey, these principles have been blatantly and detrimentally disregarded.
The (long serving 'interim') leader of the enforcement team has unlawfully abused conferred powers against nonexistent breaches of planning control or harm to amenity. Such malpractice unjustly inflicts substantial punishment on undeserving members of the public. The same arbitrary approach appears to have extended to the determination of related planning applications and appeals (for which the same official is also responsible).
It is not known if the leader has been acting on his own accord or subjected to other (councillor?) influences. This is the subject of a related request (http://bit.ly/2Capx0u - where a partial reply to the present request appears to have been inadvertently provided (?).
Enforcement misconduct damages lives, sustainable development and the economy. Unnecessary enforcement appeals are lengthy, difficult and costly (for the people suffering the injustice, and the council). In Haringey, daring to appeal to The Planning Inspectorate against misuse of enforcement powers, appears to risk recrimination by the local powers that be.
The lack of transparency facilitates denials of a situation shrouded in misinformation, this in turn enables malpractice to continue, inflicting undue harm on local interests and public resources.
In its Authority Monitoring Report, Haringey council states it wishes the public to understand and engage in the planning policy and process.
An adequate reply to this reasonable request for information, may help the likes of Councillor Alan Strickland acknowledge that evident mismanagement of planning responsibilities in Haringey is a public liability. This could hopefully help advance urgently needed reform, positive development and growth across the London Borough of Haringey.
Thank you in anticipation of your assistance with this request.
Dear Mr Levy,
Please find attached the response to your above request, sent by the service on 08 February 2018.
Many thanks,
Claire Gunn
Feedback Review Officer
Shared Service Centre | Central Team
Haringey Council
5th Floor, Alexandra House, 10 Station Road, Wood Green, London N22 7TR
www.haringey.gov.uk
twitter@haringeycouncil
facebook.com/haringeycouncil
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Dear FOI,
Executive and elected members of the council have been repeatedly informed of systemic flaws that damage public interests and resources. Instead of curbing evident and unequivocal misconduct, they continually deny and ignore arbitrary and unlawful abuse of power, or attribute it to unidentified “influences” (the subject of a parallel request http://bit.ly/2Capx0u).
The response appears to confirm that decision making powers reside exclusively with one official. (point 8). This person is purportedly ‘influenced’ by unidentified councillor pressure - free to act arbitrarily, using his significant powers punitively, regardless of planning legislation and guidance, material, moral or ethical considerations.
With such background, reticence to provide information is not surprising. Dismissing this request as ‘onerous’ conveniently allows this public liability to prevail unchecked. The partial response shows that any objective cost-benefit analysis (internal or external, qualitative or quantitative) is virtually impossible.
In summary:
The budget or cost of the planning enforcement and appeals service is unknown. (point 1). Wasted appeal costs and awards of costs made against officers for unreasonable behaviour, are also unknown. (points 5, 6 & 7). The arbitrary use of enforcement powers rather than legitimately to protect public amenity is not monitored. (point 3). An audit of the enforcement and appeal function or appraisal of costly consequences of its failures have not been carried out. (point 9, 10 & 11). Neither an index nor adequate records of enforcement cases are made reasonably accessible - seemingly failing the requirement of article 43 of the Development Management Procedure Order. (point 12). The response incorrectly suggests that all locations and addresses of sites to which enforcement notices relate are identifiable on the website. The criteria and data used by the department to analyse its own performance is questionable. (point 13).
The remit of both the Planning Inspectorate and Local Government Ombudsman is restricted in respect of planning related malpractice. The council knows that challenging abuse of its planning and enforcement powers is prohibitive for most people. Even when successfully challenged, whatever the nature and extent of their misconduct or the damage it causes, they only risk a slap on the wrist by way of limited costs awards in planning appeals. This, coupled with lack of information and accountability, appears to be relied upon. Experience over two years leading to this request is unlikely to be isolated. It has damaged public interests and council finances, preventing socioeconomic benefits and a sustainable development from materialising, contrary to policy objectives. These parameters and unfettered powers enable evident, damaging abuse. They risk encouraging alternative methods of securing favourable planning decisions in Haringey.
Mr Hermitage has kindly offered to discuss issues, but issues and experience that relate to the request period, precede the time he joined the planning team to replace Mr Minty.
To protect public resources, please only provide the information requested in parts a and b of point 5 of this request, which should be readily available to the council.
Dear Mr Levy,
I am responding only to the FOI aspects of your email. You are now asking
us to provide the information requested in a and b of point 5 of your
original request.
This was as follows:
For the period 1ST APRIL 2016 TO 31ST MARCH 2017
5) The number, and if reasonably practicable, records, of Applications for
costs lodged against the Council for unreasonable behaviour causing
unnecessary or wasted expense, in: a) appeals of refusals. b) appeals of
Enforcement Notices.
I note that in the previous request for information (dated 11 January) you
asked us to disregard that question. I think it is appropriate for us to
now log this as a stand alone request. You will receive notification of
that in due course,
Regards
Sue Dyos
Feedback Team Leader
Shared Service Centre | Central Team
Haringey Council
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Dear Mr Levy
Freedom of Information / Environmental Information Regulations Request:
LBH/7093718
I acknowledge your request for information received on 15 February 2018.
This information request will be dealt with in accordance with the Freedom
of Information Act 2000 / Environmental Information Regulations and we
will send the response by 15 March 2018
Yours sincerely,
Feedback and Information Governance
Shared Service Centre | Central Team
Haringey Council
10th Floor, Alexandra House, 10 Station Road, Wood Green, London N22 7TR
facebook.com/haringeycouncil
This email and any files transmitted with it are confidential, may be
subject to legal privilege and are intended only for the person(s) or
organisation(s) to whom this email is addressed. Any unauthorised use,
retention, distribution, copying or disclosure is strictly prohibited. If
you have received this email in error, please notify the system
administrator at Haringey Council immediately and delete this e-mail from
your system. Although this e-mail and any attachments are believed to be
free of any virus or other defect which might affect any computer or
system into which they are received and opened, it is the responsibility
of the recipient to ensure they are virus free and no responsibility is
accepted for any loss or damage from receipt or use thereof. All
communications sent to or from external third party organisations may be
subject to recording and/or monitoring in accordance with relevant
legislation.
Dear Mr Levy,
Re: Freedom of Information Act Request ref: LBH/7093718
Thank you for your request for information received on 15 February 2018,
in which you asked for the following information:
For the period 1ST APRIL 2016 TO 31ST MARCH 2017
The number, and if reasonably practicable, records, of Applications for
costs lodged against the Council for unreasonable behaviour causing
unnecessary or wasted expense, in: a) appeals of refusals. b) appeals of
Enforcement Notices.
My response is as follows:
Please note that the table below relates to appeals decided in the period
in question.
Planning Appeals – Costs Claims Against the LPA
PINS REF LPA REF ALLOWED REFUSED
3155492 HGY/2016/0542 ü
3157018 HGY/2016/1986 ü
3081118 HGY/2014/1333 ü
3134883 HGY/2015/0901 ü
3150466* HGY/2015/0522 ü
3159348 HGY/2016/1800 ü
3160349 HGY/2016/1259 ü
3136502 HGY/2015/2394 ü
· Scheme recommended for approval by officers but overturned by
members
Planning Enforcement Appeals – Costs Claims Against the LPA
PINS REF LPA REF ALLOWED REFUSED
3146620 UNW/2015/00938 ü
3158695 UNW/2014/00199 ü
Planning Enforcement Appeals – Costs Claims by the LPA against appellants
PINS REF LPA REF ALLOWED REFUSED
3154723 FCV/2014/00720 ü
The appeal decision for the above cases is on the Council’s website and
the Planning Inspectorate website.
If you are unhappy with how we have responded to your request you can ask
us to conduct an Internal Review. If so, please contact the Feedback and
Information Team as below. (Please note you should do this within two
months of receiving this response.)
Feedback and Information Team
5th Floor, Alexandra House
10 Station Road
London
N22 7TR
E [1][email address]
Yours sincerely,
Emma Williamson
Assistant Director-Planning
Regeneration, Planning and Development | Haringey Council
River Park House 225 High Road | London | N22 8HQ
Tel: 020 8489 5507
www.haringey.gov.uk<http://www.haringey.gov.uk/>
This email and any files transmitted with it are confidential, may be
subject to legal privilege and are intended only for the person(s) or
organisation(s) to whom this email is addressed. Any unauthorised use,
retention, distribution, copying or disclosure is strictly prohibited. If
you have received this email in error, please notify the system
administrator at Haringey Council immediately and delete this e-mail from
your system. Although this e-mail and any attachments are believed to be
free of any virus or other defect which might affect any computer or
system into which they are received and opened, it is the responsibility
of the recipient to ensure they are virus free and no responsibility is
accepted for any loss or damage from receipt or use thereof. All
communications sent to or from external third party organisations may be
subject to recording and/or monitoring in accordance with relevant
legislation.
References
Visible links
1. mailto:[email address]
Dear Feedback and Information Team,
Thank you for your response, the content of which has been noted. Best wishes to the talented and decent folk at Haringey planning department, who are guided by planning legislation, sound ethics and the principle of legal certainty (rather than by tyrannical influences who tarnish their positive work, to the detriment of public interests).
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