Paper A

 

Purpose : For Decision

 

Committee:      REGULATORY APPEALS COMMITTEE

 

Date:                28 FEBRUARY 2003

 

Title:                PROPOSED DEFINITIVE MAP MODIFICATION ORDER - BRIDLEWAY, COOK’S CASTLE FARM, WROXALL

 

REPORT OF THE STRATEGIC DIRECTOR OF CORPORATE AND ENVIRONMENT SERVICES

 

 

SUMMARY/PURPOSE

 

The report sets out evidence together with the legal tests to decide whether a modification order should be made to add a path at Cook’s Castle Farm, Wroxall, to the Definitive Map and Statement. There is a duty under section 53(2) of the Wildlife and Countryside Act to make an order if a period of public use has elapsed raising a presumption of dedication, or if evidence shows that a public right of way is reasonably alleged to subsist.

 

ROUTE DESCRIPTION

 

An extract from the current Definitive Map showing the general location of the claimed path and the recorded public rights of way in the area is Map 1 at Appendix 1. The claimed route is marked AB on the larger scale map, Map 2 at Appendix 1.

 

An aerial survey of the area at a scale of 1/2500 taken on 29 July 1999 is also at Appendix 1.

 

The path runs from a point on Public Bridleway V31 140 metres north of a bridle gate in the hedge boundary of OS parcels 3917 and 6843 (point A) north north east for 125 metres across OS parcel 6843 ascending gradually over open pasture in a direct line to join Public Bridleway V34 on a level area of grass at a point 150 metres south west of the entrance gate to the Southern Water St Martin’s Down Reservoir (point B).

 

1          BACKGROUND

 

1.1       Public rights over AB were most recently brought into question in discussion and correspondence between the landowner and the Council beginning in August 1999 concerning the clearance and position of a section of Public Bridleway V31 and Public Bridleway V34 (also shown on Map 2 at Appendix 1). The rights were challenged publicly when a trench was excavated across the route in mid-September 1999 and material from extensive work on the hedge and hedgerow trees was deposited. The Council took action in respect of the trenches (a second trench was dug across the Definitive route of Bridleway V31) to safeguard the public on the grounds that AB had become a highway through long user.

 

1.2             Subsequently an investigation of evidence has been carried out to determine whether a modification order should be made under s53 of the Wildlife and Countryside Act 1981 to add the route to the Definitive Map and Statement. The statutory process provides the landowner with a formal opportunity to challenge the claimed public rights. 

 

1.3              The section AC of Bridleway V31 runs alongside a hedge. The section of Bridleway V34

 


marked CB on the map climbs directly from V31 up a steep bank covered with bracken and gorse scrub to an open grassy plateau at point B.  In September 1999 there was no physical sign of CB through the vegetation, but a path was cleared and waymarked in November 1999 in response to a request from the landowner. 

 

1.4       Legal advice on the determination of modification applications is set out at section 2 and at Appendix 2. User evidence is set out in section 3 and at Appendix 3, landowner evidence at section 4 and at Appendix 4. Documentary evidence consisting of aerial photographs is at section 5 and Appendix 5. Evaluation and conclusions are set out in section 6.  Local member and parish council comments on the proposed modification, if submitted, are at section 1.5 below and at Appendix 7. Final comments of the landowner on this report are copied at Appendix 8 together with the Council’s response.

 

1.5       OUTCOME OF CONSULTATIONS

 

The Local Member and the Parish Council have been consulted and their comments if submitted are attached in Appendix 7.

 

The owner of the land over which the route AB runs has been consulted.  Evidence relating to or submitted by previous or current landowners is in section 4 below.

 

2.                  LEGAL BACKGROUND TO MODIFICATION ORDERS

 

Provisions of Wildlife and Countryside Act 1981 section 53

 

2.1       Under section 53 of the Wildlife and Countryside Act 1981 the Council as Surveying Authority for the Isle of Wight has a duty to keep the Definitive Map and Statement under continuous review by making modification orders when necessary because of certain events specified in section 53 (3).

 

2.2       The events specified in section 53(3)(a) are legal events such as diversion orders under the Highways Act, for which an automatic map modification order not requiring advertisement is made. The events specified in section 53(3)(b) and (c) are those which require the Council to consider evidence relating to a possible public right of way, or to anything currently recorded in the Definitive Map and Statement. In this case the order is made according to the procedure set out in Schedule 15 and must be advertised to allow a period of public challenge and the possibility of a public inquiry or hearing to test the evidence. 

 

2.3       The event specified in section 53(3)(b) is the expiration of any period of time such that public enjoyment of the way gives rise to a presumption of dedication of a public right of way.

 

2.4       The event specified in section 53(3)(c) is the Council’s discovery of evidence concerning a public right of way. An order should be made if on balance of probability the evidence, when considered with all other relevant available evidence, shows:

 

(i)         that a right of way which is not shown in the map and statement subsists, or is reasonably alleged to subsist over land in the area to which the map relates, being a right of way to which this part applies.

 

(ii)        that a highway shown in the map and statement as a highway of a particular description ought to be there shown as a highway of a different description.

(iii)       that there is no public right of way over land shown in the map and statement as a highway of any description, or any other particulars contained in the map and statement require modification.

 

2.5       In the case of the deletion of a right of way, because of  the conclusive evidential effect of  the Definitive Map and Statement (Wildlife and Countryside Act 1981 section 56), the evidence supporting a deletion must show that no right of way existed  at the relevant date of  the Definitive Map on which the right of way was first shown. The onus is on the applicant to demonstrate that an error has been made, rather than for the authority to prove that the Definitive Map is correct. If the authority itself has evidence of an error, it must similarly demonstrate the fact before making an order.      

 

2.6       Under section 53 paragraph (5) and according to the procedure set out in Schedule 14, anyone may apply to the authority for a modification order required under (b) or (c),  that is, may bring evidence to the attention of the authority. The authority is then under a duty to investigate that evidence, to consult with other local authorities for the area and then to determine whether to make the order.  If this determination is not made within 12 months, the applicant may apply to the Secretary of State, who, after consulting with the authority, may direct the authority to do so.

 

2.7       If the authority determines not to make the order, the applicant may appeal to the Secretary of State, who may direct the authority to make the order.

 

2.8       If the Council decides to make a modification order, it must be advertised for not less than 42 days and if there are any objections  which are not withdrawn, it must be referred to the Secretary of State for determination and a public inquiry will usually be held.

 

Effect of the Definitive Map

 

2.9       Under section 56 of the Wildlife and Countryside Act 1981, the Definitive Map is conclusive proof of the existence and status, at the relevant date of the map, of the rights of way that are shown, but without prejudice to the possibility that further rights may exist. The Definitive Statement is conclusive proof of the details  which it contains as to width, position and any conditions or limitations on the rights of way shown on the Definitive Map.

 

2.10     The original Definitive Map and Statement for the Isle of Wight was made under the National Parks and Access to the Countryside Act 1949 and has a relevant date of 11 November 1952. It was reviewed under the same act with a relevant date of 8 February 1968. On both occasions it went through all the necessary stages when challenges could be made. The advice of the Department of the Environment is that such documents are presumed correct unless there is cogent evidence that an error was made.  The current Definitive Map and Statement has a relevant date of 29 February 2000.

 

2.11     Dedication of Highways

 

The question which usually has to be determined by the Council when considering a modification order is whether the evidence shows that a highway exists because dedication has occurred at common law or is deemed by operation of section 31 of the Highways Act 1980. Where this question is a relevant issue, the Department of the Environment’s guidance notes for inspectors on the dedication of highways are copied in full at Appendix 2. Evidence concerning dedication should be interpreted in the light of the principles set out, but note that the advice there given is amended in the light of the Sunningwell decision in 1999 (see Planning Inspectorate Advice Note No 6 attached at Appendix 2) to the effect that in deciding whether use is as of right, it is no longer necessary to consider the belief of the users. It is only necessary to be satisfied that use by the public was without force, without stealth, and without permission. 

  

2.13     Once public rights are dedicated over a way, that way becomes a highway and exists in perpetuity unless stopped up or diverted by statutory order.  The highway does not cease to exist because it is not used, hence the maxim ‘once a highway, always a highway’. 

 

2.14     Quasi-Judicial role of the Council

 

In considering the evidence, the Council is acting as a tribunal of fact and is required to:

 

1.         Objectively consider all the available relevant evidence, taking advice as to application of legal principles where necessary, and come to a conclusion, on balance of probability, on matters relating to the existence of public rights of way in order to determine whether a modification of the Definitive Map and Statement is required. Such matters may include whether a presumption of dedication is raised, whether such a presumption is negated, whether a right of way subsists, details relating to position and width, or to limits or conditions on a dedication.

 

2.         Disregard all views which are not relevant to the fact which has to be found.  Such views may concern for example the effect or desirability of the right of way should it be found to exist.

 

3.         Apply the principles of natural justice. The decision itself will depend upon the facts and law, but in making that decision it is important that persons who will be affected by the order if made, notably the landowner and occupier, have sufficient opportunity to put evidence forward themselves and to comment on the evidence being considered by the Council. The Council should therefore consider only the evidence and comments presented in writing in the report, which the landowner will have seen and had the opportunity to comment on.

 

3.         WITNESS EVIDENCE - USER

 

3. 1      24 witness statements have been completed, 4 on behalf of husband and wife. In nearly all cases, user has been confirmed by interview. 2 witnesses are related to the previous owner and their user is not included in the table. User evidence is summarised in the bar chart at Appendix 3. 

 

3.2.1        Whether walking or on horseback, all the witnesses stated that they used the route AB as a matter of course as a public right of way and that ‘everyone did so’. None had sought or been given permission, none had been challenged or been told to use any other route. Witnesses described AB as the natural direct route across open ground when going towards the reservoir, St Martin’s Down and on to Shanklin, whereas using ACB would involve making an illogical detour to go up a steep bank covered in scrub. Long-term users said the parcel of land had originally been grazed and therefore more open, but that scrub cover had gradually increased in the last fifteen to twenty years. 

 

3.3       Witnesses stated that there were no notices or signs or obstructions on or near the route until recently, that is in September 1999 when work was carried out on the hedge and trees. At that time tree trunks and branches were left across the path and then ditches were dug. Fence posts were erected but no wire so the route could still be used.  This work was the first indication of any problem with using the route.  Witnesses have continued to use it by going round any obstructions. 

 

3.4       Witnesses living in Wroxall and coming from the direction Castle Road said that when  the new water main was being put in approximately along the route of AB down to Castle Road, they could continue to walk the path by going round the construction works. Some riders recalled problems when coming from the direction of the reservoir site towards Wroxall, as construction site fencing left only the route along the hedge which was narrow and muddy, and they had to suspend their use during this time. Some users avoided the area during the construction period because of the muddy conditions.

 

4.         WITNESS EVIDENCE - LANDOWNERS/OCCUPIERS

 

4.1       The owner during the period 1968 to 1994 has been interviewed. The land which now forms part of Cook’s Castle Farm was then part of Yard Farm.  He confirmed he did not put up any notices on AB or anywhere on the definitive route of Bridleway V34, although he did put one on the gate across the reservoir access road leading down to Yard Farm. He said that riders would use the direct route between the bridle gate at the bottom of the field and the gate by the reservoir, ie use the route AB. He said they were not supposed to and that he would point them to the correct route by the hedge. He never objected to walkers using AB. However he also said he did not object to people riding anywhere as long as it was not through crops. He considered fencing the bridleway in but never did so. He referred to CB being a farm track which continued approximately on the route of Public Footpath V32, made and used by himself leading up to up to arable fields.

 

4.2       The current owner has owned the land since 1994. In a letter to the Council dated 23 August 1999, the owner says that the public use the route AB instead of the definitive route ACB because the latter is obstructed by vegetation due to the Council’s neglect of its statutory duty to remove surface vegetation and that use of AB is therefore a deviation of Bridleway V34 forced on users by the Council’s lack of maintenance, rather than the dedication of a separate path.

 

4.3       The same letter draws attention to the fact that no additional routes are capable of being claimed because of the plan and statement deposited by her under section 31(6) of the Highways Act 1980 in February 1997, and therefore the use of AB by the public can only be permissive.

 

4.4       The current owner has made a submission of evidence including an aerial photograph dated 1979 and an amended version of the statement given to the Council by the previous landowner. The landowner summarised her evidential argument verbally at a subsequent meeting with officers and also submitted notes of five interviews with user witnesses.  These documents and the officer’s file note of these points are at Appendix 4.

 

5.         DOCUMENTARY EVIDENCE

 

5.1       Aerial Surveys held by the Council’s Corporate and Environment Services dated 1971, 1979, 1986, 1993 and 1999 have been examined. The scale of the photographs varies between 1/5000 and 1/10,000.

 

5.2       The aerial photographs are at a relatively small scale and features are indistinct unless strongly marked. What can be seen is that in 1971 there was a path or track available over CB between two areas of scrub, AB was open grassland as at present with no strongly marked route.  V31 and V49 were well-worn tracks connecting with Yard Farm buildings and Castle Road.  A number of paths and tracks are evident in 1979. CB is still strongly marked and a path diverting from V31 corresponding to AB is also apparent. By 1986 there is more scrub in the region of CB and it may or may not be available as a path, while AB appears to be open through patches of scrub on either side. By 1993, AB is strongly marked over open grassland and no path is marked over CB  which appears to be scrubbed over. 

 

6.         ANALYSIS OF EVIDENCE AND CONCLUSION

 

6.1       The events of September 1999 first drew to the attention of the public using the way that their rights were being called into question in terms of the provisions of section 31 of the Highways Act 1980 and it was these events that precipitated the claim process. The statutory period of use would be 20 years counting back from this date, ie 1979 to 1999.

 

6.2       However, the landowner’s evidence shows that the rights were first brought into  question in February 1997 when she deposited a plan and statement under the Highways Act 1980 s 31(6) which did not include the route AB as an admitted highway. There is no evidence of public rights being brought into question in any way prior to the date of the deposit. Accepting the owner’s deposit under s31(6) was a calling into question, even though this was not a public challenge, the earliest possible statutory period would be1976 to 1996.

 

6.3       The table shows that there has been continuous use of the route AB by the public on foot and on horseback since 1968 and on foot as far back as 1940.  As far as can be ascertained from witness statements and interviews, this use meets the criteria for use as of right. All witnesses asserted they were using the route as a public right of way.

 

6.4       It is not possible to determine from aerial photographs whether routes are used by the public, only what is physically apparent.  A route being used may not be physically apparent. Bearing this in mind, the following inferences can be made. Before the relevant period a route CB, the Definitive route of V34, was available because it was being used by Mr Hayles and could have been used by the public. According to Mr Hayles’ statement, he used this route to reach the track he had made on or close to the route of Footpath V32 to reach his fields.  By 1986, after the reservoir road was built, the tracks in the area are less marked and there is more scrub, leading to the conclusion that there was less farm traffic and less grazing. CB appears to have disappeared beneath scrub, but there has always been a way open for AB and by 1993 the route AB is clearly visible.

 

6.5       The landowner has suggested that AB is only a deviation used by the public because the route of CB was not kept clear of scrub.  However, at the beginning of the period of use, CB was available. No witness mentioned inability to use CB as the reason for using AB, but confirmed the reason for using AB was that it is a more convenient route than ACB in terms of length and directness, and in terms of gradient and surface vegetation.  A landowner or user could have drawn the need for maintenance to the attention of the Council at any time and the Council would have responded. It is only in the last three years that path clearance has been carried out as a proactive programme and it is normal for a large amount of the Council’s maintenance duties to be carried out in response to reports and requests. It is reasonable to conclude that the route was used in preference to CB as a better route. Although there is a common law right to deviate round an obstruction (which may result in the dedication of a greater width), AB is physically separated from CB and must be considered as a separate route which the landowner could have challenged.

 

6.6       Dedication is deemed by operation of section 31 unless there is sufficient evidence during the statutory period of the landowner’s intention not to dedicate. The only evidence of no intention to dedicate is a statement by the previous landowner Mr Hayles that riders were trespassing in using AB and that he directed them to the bridleway by the hedge by pointing to it. However he also says in his statement that he had no objection to riders on the land except through crops and none of the witnesses reported experiencing a challenge. Although in the earlier years of his ownership he was actively farming, he did not take any steps during 26 years of ownership to express on a more effective and permanent basis his intention not to dedicate, for example by notice, although he did do so on another route nearby. In order to negate deemed dedication under section 31, the owner’s intention must be made explicit in such a way as to have a reasonable chance of being received and understood by the public using the way as a challenge to their rights.  If notices are torn down, the remedy is to notify the Council under that section. 

 

6.7       The current landowner’s submission makes the following main points of evidence. These are evaluated in corresponding sub-paragraphs of paragraph 6.8 below:

 

(1)        The Ramblers’ Association survey of 1974 did not identify any path in use that diverged from the definitive line so the definitive line must have been in use;

 

(2)        There was no challenge from the public or the Highway Authority when AB was fenced off for 18-24 months by Southern Water during the laying of the water main to the new reservoir in 1980/1;

 

(3)        There was no possible route for horse riders during this period, although a temporary pedestrian route was possible;

 

(4)        Aerial photographs 1979 and 1983 show the route used by the public changed between these two dates;

 

(5)        The 1979 photograph shows only one worn route so this must be the path, and not AB, that witnesses are referring to when they say there was only one route;

 

(6)        Points A and B are in gorse so the route being claimed as used cannot be AB;

 

(7)               That in his amended statement the previous landowner makes it clear that he did not condone haphazard public use of his land.

 

6.8       (1)        In this letter the assumption is being made that AB is the Definitive route of V34, and therefore it is this route which is being compared to the proposed new route. No doubt the same assumption was made by the surveyor in 1974 when  the definitive route was found to have no problems.

 

(2, 3)    The authority was aware of the effect of the construction work on the rights of way and had been consulted by Southern Water. The water main does in fact run over the route of V34 for much of its distance and a temporary closure order would have been required while it was laid. Whether or not such an order was obtained, such a closure would be a temporary suspension of the right of way to permit construction work by statutory undertakers. It would not represent a challenge or interruption by the landowner to the rights of the public as required under the Highways Act s31 in order to negate a presumption of dedication. At least one witness stated that it was possible to continue walking the route by going round the water main fencing. Witnesses agree that the reservoir construction caused disruption both at the site of the reservoir itself and along the pipe line. Although some people gave up using the route as too muddy, others went around the obstructions as best they could, whether to the north west or the south east. It is clear they understood the rights to be temporarily diverted for practical reasons and not as a challenge to the rights of way which they were still exercising in some fashion. Given that the reservoir was benefiting the village and some users directly, they would not necessarily complain to the authority.

 

(4, 5)    Many routes and tracks are apparent on the 1979 photograph including the claimed route. No 1983 photograph has been submitted; it is assumed the 1986 photograph is being referred to. The claimed route AB is available. The photographic evidence does not support either of these points.

 

(6)        Although passing close to scrub, the claimed route AB has been checked by using an accurate Geo-Positioning System (GPS). Both points A and B are available.

 

(7)               Both versions of the previous landowner’s statement make it clear that no overt actions of the kind required to negate deemed dedication were taken on the claimed route AB except some personal challenges from a distance to horse riders which were admitted to be ineffectual. Witnesses who were horse riders stated they believed themselves to be using a public right of way. 

 

6.9       It is concluded that a right of way is reasonably alleged to exist on grounds of deemed dedication under section 31 of the Highways Act 1980 in consequence of an uninterrupted period of public use as of right between 1976 and 1996 during which there is insufficient evidence of an intention not to dedicate.  A modification order should be made under s53(3)(c) to add the route AB to the Definitive Map and Statement as a bridleway with a width of 2 metres.

 

FINANCIAL IMPLICATIONS

 

None outside current budgets.

 

IMPLICATIONS UNDER THE CRIME AND DISORDER ACT 1998

 

The Council has a duty to make an order to modify the Definitive Map and Statement or not according to its conclusions on the evidence. Should a right of way be confirmed, any powers that may be available to the Council with respect to Public Paths for the purposes of reducing Crime and Disorder could be considered. However it is not considered that there will be any specific implications in this case as there are already other established rights of way in the same field parcel.

 

IMPLICATIONS UNDER THE HUMAN RIGHTS ACT

 

In making the recommendation to make the modification order consideration has been given to the implications of the Human Rights Act.

 

In respect of Article 6 (right to a fair trial) of the European Convention on Human Rights it is considered that by advertisement of the proposed order and submission of the report to the landowner for comments the Council has met the requirements of this Article.

 

In respect of Article 8 (respect for private and family life) and Article 1 of the First Protocol (protection of property), the impacts that the modification might have on the owners of this property and on owners of other property in the area and users of the paths before and after modification have been carefully considered. Whilst there may be some interference with the rights of the owner it is considered that the recommendation to modify is proportional to the legitimate aim of the Council and in the public interest.

 

OPTIONS

 

The Council has a duty to make an order to modify the Definitive Map and Statement or not according to its conclusions on the evidence. 

 

RECOMMENDATIONS

 

That a modification order be made to add the route shown AB on Map 2 at Appendix 1 as a bridleway with a width of 2 metres.

 

 

BACKGROUND PAPERS

 

Aerial Photographic Surveys held by IWC Archaeological Unit 1971, 1979, 1986, 1993

Aerial Photographic Survey held by IWC, Highways and Transportation, 1999

IWC Archaeological Unit GPS Route Survey

HM Land Registry Plan Title No. IW32509 Edition 22.12.99

DoE Guidance Notes on Evidence 1989

Planning Inspectorate Advice Note No 6 Oct 2000 re Sunningwell Judgement

24 Witness Statements

17 File notes of Interviews

IWC Interview with Mr J Hayles

Highways Act 1980 s31(6) Deposited Plan and Statement submitted by Ms Perrott 27.2.79

IWC to Ms Perrott Acknowledgement of Receipt of Deposit 3.3.97

Letter IWC to Councillor Yates 16.10.99

Letter IWC to Wroxall Parish Council 16.10.99

Letter Wroxall Parish Council to IWC 15.11.00

Letter Ms M Perrott to IWC 23.8.99

Submission and comments Ms M Perrott to IWC

RWA/V901 File note 20.11.01

Wiitness Interview notes Ms M Perrott to IWC 20.11.01

 

APPENDICES

 

PLEASE NOTE - Appendix 1 is attached to the report.  Copies of Appendices 2 – 9 are available on application to Committee Services. Tel 01983 823282.

 

Appendix 1 :  Route Description

 

1.                  Map 1: Definitive Map 2000 showing public rights of way currently recorded in area

2.                  Map 2: Plan of claimed route AB

3.                  Most recent (1999) aerial survey of the area

 

 

 

Appendix  2 :  Legal Background to Modification Orders

 

1.                  Guidance Notes on Evidence of Dedication issued by Department of the Environment 1989

2.                  Planning Inspectorate Advice Note No 6 Oct 2000 re Sunningwell Judgement

 

Appendix 3 :  User Evidence

 

1.                  Table of  User Evidence

 

Appendix 4 : Landowner Evidence

 

1.                  Highways Act 1980 s31 Deposited Plan : Ms M Perrott 27.2.97 (3 pages incl map)

2.                  Letter Ms M Perrott to IWC 23.8.99 (1 page)

3.                  Letter Ms M Perrott to IWC 20.9.01 : Submission of Evidence (13 pages incl 2 maps)

4.                  Letter Ms M Perrott to IWC 9.11.01 : Submission of Documents relating to Submission of Evidence above (8 pages incl 2 photos):

(i)         Amended Statement of previous landowner Mr J Hayles obtained by Ms Perrott (3 pages incl map)

(ii)                Copy of letter Mr R Smith to Mrs J Deacon 27.10.96 and notes (3 pages)

(iii)               Copy of letter IWC to S Water 8.3.00

(iv)              Copy of heading of letter S Water to Ms M Perrott  14.12.00 with attached copy of letter signed Fred Caws (1 page)

(v)                Aerial Survey 1979 and enlarged extracts (4 pages)

5.         Interview Ms M Perrott and IWC Officers 20.11.01

(i)         IWC File RWA/901 Officer’s Note of Interview 20.11.01 including two extracts from 1979 Aerial Survey Photograph illustrating Point 2

(ii)        Notes of 5 interviews with witnesses submitted by Ms M Perrott during interview

 

Appendix 5 :  Documentary Evidence

 

1.                  Aerial Survey 1971

2.                  Aerial Survey 1979

3.                  Aerial Survey 1986

4.                  Aerial Survey 1993

 

Appendix 6 : Analysis of Evidence and Conclusion

 

No items

 

Appendix 7 :   Comments of IWC Local Member and Parish / Town Council

 

1.                  Letter Wroxall Parish Council to IWC 15.11.00 

 

Appendix  8 : Comments of current landowner on final report and Council’s response

 

1.                  Letter Ms M Perrott to IWC 28.10.02 (7 pages incl copy letter and list of comments)

2.                  Amended Summary of Evidence with reference list of documents and copies of items CC32, 35, 37, 39, 41,43, 47,48 on this list (20 pages).

3.                  Officer’s response to landowner’s comments.

 

Contact :  Alex Russell (ext 3740), Rights of Way, Engineering Services

                                                            M J A FISHER

                                    Strategic Director, Corporate and Environment Services