HomeMy WebLinkAbout2560410 - F.I. Received Doc. - Application - Cover Letter
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Planning re.no. 25/60410
Date: 16/06/2026
Re: FI Response ‐ retention of internal alterations to previous approved plans under
20/155 including the following: 1. Conversion of attic of 528.41sq.m. floor area for the
provision of 9 no. bedrooms, associated stairs and lift core. 2. Alterations to previously
approved layout of ground floor in relation to 11 no. bedrooms, storage and staircase
locations. 3. Alterations to previously approved layout on first floor in relation to
bedroom, storage and staircase locations. 4. Repurposing of existing ground floor
meeting room (62.00sq.m.) to additional kitchen and laundry facilities. 5. All
associated site development work at Treacys Hotel, Losset, Kingscourt Road,
Carrickmacross, Co. Monaghan
Dear Mr. Clerkin,
Further to your letter dated 8 December 2025 requesting Further Information in respect of
the above application, the following response is submitted on behalf of the applicant.
The subject application seeks retention permission for internal alterations to a previously
permitted hotel building under Planning Ref. 20/155, including the conversion of attic floor
space to provide 9 additional bedrooms together with associated stairs and lift core,
alterations to previously approved internal layouts, the repurposing of an existing meeting
room to provide additional kitchen and laundry facilities, and all associated site development
works.
At the outset, the applicant wishes to clarify the scope of the application.
The premises is currently used to provide accommodation for persons seeking international
protection under arrangements with the State. The planning status of that use is the subject
of a separate Section 5 Declaration request (Ref. EX25/102), which remains under
consideration by Monaghan County Council.
Accordingly, the information provided in response to this Further Information request is
intended to assist the Planning Authority in its assessment of the retained works and the
planning considerations arising therefrom, including matters relating to servicing,
environmental capacity, fire safety, accessibility, transport, occupancy and internal layout.
For completeness, it is noted that the retained works are capab le of serving either hotel/guest
accommodation or accommodation for persons seeking international protection. The
applicant's long‐term intention remains the return of the premises to conventional hotel
operation when the current requirement for such accommodation no longer arises. RECEIVED: 16/06/2026
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FI Request Point 1.
“It is the Planning Authority’s understanding that the property has not operated as a
commercial hotel for a considerable period and is currently being used exclusively as
accommodation for protected persons.
Accordingly, in the interest of clarity and transparency, please provide a formal statement
confirming:
(a) The date the premises ceased operating as a commercial hotel, and the date the
premises commenced use as accommodation for protected persons.
(b) Confirmation that the premises is not currently operating as a hotel and has no active
commercial hotel function.
(c) Your client profile, and confirmation from the relevant State agency that these
individuals fall under the definition of protected persons.
(d) Details of contractual arrangements with State agencies governing the current and
proposed use of the premises”.
Response
(a) Dates of operation
The premises was first granted permission for accommodation use pursuant to Planning
Permission Ref. 97/55 2 (which permitted development described as follows: “Retain 35 no.
bedrooms incl. facility for disabled people, new restaurant, the roofing and complete
refurbishment of the already existing night club known as the Oasis nite club” (emphasis
added).
It became operated as a hotel, which is reflected in the terms for the permission under Reg.
Ref. 17/115 which refers to a permitted development comprising –
“works to an existing hotel including change of use of a ground floor night club area to 7no.
Bedrooms, kids play zone, games room, toilets and storage areas, demolition of various
storage areas to rear, alterations to all elevations including reconfiguration of the existing
main entrance, extensions to side and rear, demolition of single storey dwelling and
replacement and relocation of same with two storey dwelling to southeast of site,
rearrangement of the existing car parking areas, revisions to the existing main vehicular
entrance, landscaping and all associated site development works…” [Emphasis added]
Both of these permissions endure for the benefit of the land (see Planning and Development
Act 2000, as amended, s. 39(1)). The effect of this latter provision is that the permitted
development cannot be abandoned: see Molloy v Minister for Justice, Equality and Law
Reform [2003] 2 IR 493. RECEIVED: 16/06/2026
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The applicant confirms that the premises has been used to provide accommodation for
persons seeking international protection since 2020. However, The first formal contractual
arrangement with the State under the current contractual framework commenced in July
2023. In December 2023 the hotel closed to members of the public.
The planning status of that use is the subject of a separate Section 5 Declaration request (Ref.
EX25/102), which remains under consideration by Monaghan County Council.
(b) Current operation
The premises currently provides bedroom‐based centrally managed guest accommodation
for persons seeking international protection, together with associated servicing,
management and support arrangements.
While the premises is not presently marketed through conventional commercial hotel
booking channels, the building remains physically capable of operating as hotel/guest
accommodation and retains the layout, infrastructure and servicing characteristics associated
with that use. No planning permission would be required for the resumption of that use
having regard to Planning Permission Ref. 97/552, inter alia, to retain 35 no. bedrooms,
permission Reg. Ref. 17/115, which have been referred to above, and also Reg.Ref. 20/155.
It is further noted that the authorised hotel/guest accommodation use benefits from the
planning permissions attaching to the land. No condition attached to Planning Permission Ref.
20/155, or any preceding permission relating to the development of the premises, restricts
the operation of the building to a particular commercial model, requires occupation by a
particular category of guest, or requires the premises to revert to open commercial hotel
trading within a specified period. The applicant's long‐term intention remains the return of
the premises to conventional hotel operation when the current requirement for
accommodation of persons seeking international protection no longer arises.
Without prejudice to the applicant's position in the Section 5 process, it is submitted that the
accommodation of persons seeking international protection within the premises has not
resulted in any measurable additional material planning impacts when compared with the
authorised hotel/guest accommodation use. In particular, no material distinction arises in
respect of occupancy assumptions, wastewater loading, transport demand, servicing
requirements, fire safety considerations or environmental effects relevant to the retained
works the subject of this application.
RECEIVED: 16/06/2026
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(c) Client profile
Residents accommodated within the premises fall within the relevant State‐administered
categories of persons seeking international protection. Confirmation from the relevant State
authority is enclosed.
(d) Contractual arrangements
Accommodation is provided under contractual arrangements with the relevant State
authority.
The applicant confirms that the premises is currently used by the State in assisting with the
accommodation of persons seeking international protection. The details of contractual and
procurement arrangements between the applicant and the relevant State authority are
operational matters and do not alter the physical characteristics of the development or the
planning considerations arising from the retained works the subject of this application.
FI Request Point 2
“During the assessment of planning file number 20/155, the applicant confirmed that the then
current use of the premises for accommodating protected persons was temporary and stated
that the purpose of the proposed works was to make the hotel commercially viable, with the
intention to revert to full hotel use upon completion.
Accordingly, in the interest of clarity and transparency, please provide:
(a) A formal explanation as to why the premises did not revert to commercial hotel use
following completion of works under 20/155.
(b) Confirmation of whether the commitments made in the Further Information response
for 20/155 were fulfilled, and if not, why.
(c) Details of any change in operational strategy since the submission and grant of
20/155, including correspondence or agreements with State agencies that influenced
this change.
(d) An explanation of how the current proposal aligns with the original rationale
presented under 20/155, and whether the development now sought is intended to
support hotel use or continued protected persons accommodation”.
RECEIVED: 16/06/2026
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Response
(a) and (b) Statements made during the assessment of Planning Ref. 20/155
The applicant acknowledges that, during the assessment of Planning Ref. 20/155, it was
indicated that the intention was to return the premises to conventional hotel operation
following completion of the permitted works.
That statement accurately reflected the applicant's intentions and the circumstances
prevailing at the time the Further Information response was submitted. However, it was an
indication of intention and is not a binding term of the permission, as such. While the
premises was expected to return to conventional hotel operation following completion of the
permitted works, circumstances subsequently evolved. In particular, the ongoing
requirement on the part of the State for accommodation for persons seeking international
protection continued beyond what had originally been anticipated and the premises has
remained available to assist in meeting that requirement.
The applicant notes that Planning Permission Ref. 20/155 is defined by its approved plans and
conditions. No condition attached to that permission required the premises to revert to
commercial hotel operation by a specified date, nor was any condition imposed restricting
occupation of the premises to a particular category of guest.
Statements made by or on behalf of the applicant during the assessment process reflected
the circumstances and intentions prevailing at that time. Such statements do not form part
of the operative permission unless expressly incorporated into a condition of that permission.
(c) Operational arrangements
The Planning Authority has requested information regarding changes in operational
arrangements since the grant of Planning Ref. 20/155.
The applicant confirms that the premises is currently used to provide accommodation for
persons seeking international protection under arrangements with the relevant State
authority and are subject to oversight by that authority.
The details of those arrangements are operational matters. From a planning perspective, the
retained works the subject of the current application do not give rise to any measurable
additional material planning impacts arising from such arrangements, having regard to
servicing, environmental capacity, wastewater loading, transport demand, fire safety
considerations and the physical characteristics of the building.
RECEIVED: 16/06/2026
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(d) Relationship between the current proposal and the rationale underlying Planning Ref.
20/155
The retained works the subject of the current application comprise internal alterations and
the provision of additional bedrooms within an existing building which has permission for
overnight accommodation..
The additional rooms have permission to be used either hotel/guest accommodation use or
accommodation for persons seeking international protection and do not alter the external
appearance, overall function or servicing characteristics of the building.
The applicant's long‐term intention remains the return of the premises to conventional hotel
operation when the current requirement for accommodation of per sons seeking international
protection no longer arises.
The planning status of the current accommodation use is the subject of a separate Section 5
Declaration request (Ref. EX25/102), which remains under consideration. The present
application relates solely to the retained physical works and should be assessed having regard
to the planning merits and impacts of those works.
FI Response Point 3
The County Development Plan 2025‐2031 does not set out a dedicated zoning or development
policy for protected persons accommodation/IPAS centres, but your proposal can be assessed
with respect to the proper planning and sustainable development of the area, particularly
concerning the suitability of the location and the standards of accommodation. As per the info
submitted, it is unconfirmed if the further development and internal reconfiguration of the
former hotel would be acceptable. It is noted that the existing building(s) was designed and
permitted exclusively for hotel use, which carries different assumptions in relation to
occupancy duration, communal facilities, servicing, fire safety,
waste loading, and amenity requirements.
Accordingly, in the interest of clarity and to allow for a fully informed decision, please submit
a detailed planning statement clarifying the operational model, including information on:
(a) The number of individuals currently housed, and the number that would be housed.
(b) Current management and staffing levels.
(c) Service provision and social supports – for example, concerning language, religion,
education, and employment.
(d) Management protocols – regarding security, complaint handling, emergency services
access, and safeguarding measures for vulnerable persons.
(e) All bedrooms and shared facilities. Same should meet minimum accommodation and RECEIVED: 16/06/2026
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public health standards, particularly regarding room sizes, natural ventilation and
lighting, sanitary provision per occupant, kitchen capacity, laundry capacity, and
communal areas/amenities for all ages.
(f) Waste management.
The statement should reference the 2019 National Standards for Accommodation Offered to
People in the Protection Process.
Response
The applicant acknowledges the Planning Authority's request for additional information
regarding the operational context of the premises and the standards of accommodation
provided therein.
Before responding to the individual matters raised, the applicant wishes to clarify a number
of points arising from the wording of the Further Information request.
The present application relates solely to the retention of internal alterations and the provision
of 9 additional bedrooms within an existing authorised accommodation building. The
application concerns the physical works carried out within the existing building and the
planning implications arising from those works, including matters such as servicing,
wastewater capacity, fire safety, accessibility and transport.
The applicant also notes that a number of assumptions contained within the Further
Information request do not accurately reflect the characteristics of the development. In
particular, hotel and guest accommodation buildings are designed and assessed having regard
to maximum occupancy, peak loading, servicing requirements, fire safety standards and
environmental capacity. These considerations are not determined by the identity or legal
status of occupants.
Similarly, matters such as wastewater generation, fire safety design, transport demand,
circulation, accessibility and servicing infrastructure are assessed by reference to occupancy
and capacity considerations rather than the category of persons accommodated within the
building.
Accordingly, the information provided below is intended to assist the Planning Authority in
assessing the retained works having regard to the actual planning impacts arising from the
development and the operational context in which the premises currently functions. RECEIVED: 16/06/2026
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(a) Occupancy and Accommodation Provision
The premises currently provides bedroom‐based centrally managed accommodation for
persons seeking international protection together with associated communal facilities,
management arrangements and support services.
The retained development the subject of this application comprises internal alterations and
the provision of 9 additional bedrooms within the existing building envelope.
The accommodation provided remains bedroom‐based accommodation as initially permitted
under Reg. ref. 97/552 with shared facilities and common areas. The retained works do not
alter the overall operational characteristics of the building and do not give rise to any
additional material planning impacts beyond those associated with the authorised
accommodation use of the premises.
(b) Fire Safety and Accessibility
The applicant notes that compliance with fire safety and accessibility requirements is
regulated through the separate statutory Building Control system. In this regard, the
Development Management Guidelines for Planning Authorities recognise that matters
relating to compliance with the Building Regulations, including detailed fire safety
requirements, are generally addressed through the Building Control process rather than
through the planning application process.
Matters relating to compliance with fire safety and accessibility requirements are addressed
through the Building Control regime and associated statutory certification processes.
Nonetheless, a Fire Safety & Disabled Access Certificate have been granted and a Certificate
of Compliance on Completion was submitted to Monaghan County Council on the 4th April
2024 for the works granted under planning application 25‐155 and included the construction
of the 9 no. additional bedrooms which are the subject of this planning application.
Monaghan County Council placed these works on the Building Control Management System
(BCMS) register on the 20th May 2024. See Notification of Entry onto Register‐ Certificate of
Compliance on Completion attached.
(c) Transport and Accessibility
The premises is served by existing road infrastructure and benefits from dedicated transport
arrangements linking the site with Carrickmacross town centre and surrounding services. RECEIVED: 16/06/2026
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A transport timetable accompanies this submission and demonstrates the availability of
regular scheduled transport services to and from the premises.
The retained works the subject of this application do not result in any material change to the
transport characteristics of the development and do not give rise to any measurable
additional material traffic or transport impacts.
(d) Wastewater Treatment and Servicing Capacity
The premises is served by an existing wastewater treatment system designed to
accommodate a loading of 290 population equivalent (PE).
Confirmation from Mitchell Environmental Ltd. accompanies this Further Information
response and confirms that adequate treatment capacity exists to serve the retained
development.
The wastewater treatment system has been designed having regard to occupancy and loading
assumptions and is capable of accommodating the retained development without alteration
or upgrade.
Accordingly, no wastewater capacity, environmental capacity or servicing issues arise in
relation to the retained works.
(e) Management Arrangements and Standards of Accommodation
Management arrangements, safeguarding procedures, staffing levels, resident supports and
compliance with the 2019 National Standards for Accommodation Offered to People in the
Protection Process are subject to separate regulatory and contractual oversight by the
relevant State authorities.
The applicant further notes that the contractual and licensing arrangements governing the
accommodation of persons seeking international protection require ongoing monitoring and
inspection by the relevant State bodies to ensure compliance with applicable standards and
contractual obligations. As such, these matters are subject to a separate and continuing
regulatory framework.
While these matters provide useful operational context, they are not determinative of the
planning assessment of the retained development, which falls to be considered having regard
to the physical works proposed, environmental capacity, servicing arrangements, wastewater
capacity, accessibility, transport and other relevant planning considerations. RECEIVED: 16/06/2026
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In that regard, the accommodation of persons seeking international protection within the
premises has not resulted in any measurable additional material planning impacts when
compared with the authorised hotel/guest accommodation use.
Having regard to the foregoing, it is submitted that the retained works are adequately served
by existing infrastructure and services, comply with the relevant fire safety and accessibility
requirements, and do not give rise to any measurable additional material planning impacts.
FI Response Point 4
“The information submitted is insufficient with regards to transport and accessibility for
residents. Accordingly, please submit a comprehensive transport plan for the facility, outlining
a free, reliable and regular service, which would have sufficient capacity (for existing and
proposed occupancy levels) covering weekdays, evenings and weekends.
The plan should also demonstrate how these arrangements would comply with pertaining
IPAS guidelines, i.e. for accommodation located more than 2km from a large town. Supporting
documentation, such as service timetables and any agreements with transport
providers, should be included”.
Response
The applicant acknowledges the Planning Authority's request for clarification regarding
transport arrangements serving the premises and access to services and facilities.
The premises is located on Kingscourt Road, Carrickmacross and is served by the existing
public road network. The site benefits from established access arrangements and has
historically operated as hotel/guest accommodation, generating movements associated with
guests, visitors, staff, servicing and deliveries.
A transport timetable accompanies this Further Information response and demonstrates the
availability of regular scheduled transport services between the premises and Carrickmacross
town centre.
Carrickmacross is a substantial service centre providing a broad range of retail, commercial,
educational, healthcare, community, recreational and employment facilities. The transport
arrangements currently serving the premises facilitate access to these services and ensure
connectivity between the site and the town centre throughout the day.
The applicant notes that the retained development the subject of this application comprises
internal alterations and the provision of 9 additional bedrooms within an existing authorised
accommodation building. The retained works do not alter the existing access arrangements RECEIVED: 16/06/2026
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serving the site, do not require modifications to the surrounding road network and do not
give rise to any measurable additional material traffic or transport impacts.
Accordingly, the transport arrangements currently serving the premises provide an
appropriate level of connectivity to local services and facilities and are considered adequate
to serve the retained development. No transport, accessibility or road safety concerns arise
in relation to the retained works the subject of this application.
FI Response Point 5
“In the interest of health and safety, particularly given the change from temporary hotel
guests to longer‐term occupants, please submit a report by a Chartered Fire Engineer
confirming that the facility is, and would be, fire safety compliant. Points of note include
adequacy of the attic accommodation, suitability of escape stairs, corridor widths, smoke
ventilation, evacuation arrangements for the existing and proposed occupancy, and adequacy
of fire detection and suppression systems”.
Response
The subject application relates to internal alterations and the provision of 9 additional
bedrooms within an existing authorised accommodation building only. The retained works
are confined to the internal arrangement of the building and do not alter the external form
of the structure.
On behalf of the applicant it is noted that matters relating to fire safety are regulated through
the separate statutory Building Control system and are subject to assessment under the
Building Regulations. In this regard, the Development Management Guidelines for Planning
Authorities recognise that planning authorities should generally avoid imposing conditions
relating to consents or assessments which relate to other statutory codes and regulatory
systems, and this is the position that has been adopted by the Irish courts (see Ashbourne
Holdings Ltd v An Bord Pleanala [2003] 2 IR 114, Supreme Court)
A Fire Safety & Disabled Access Certificate have been granted and a Certificate of Compliance
on Completion was submitted to Monaghan County Council on the 4th April 2024 for the
works granted under planning application 25‐155 and included the construction of the 9 no.
additional bedrooms which are the subject of this planning application. Monaghan County
Council placed these works on the Building Control Management System (BCMS) register on
the 20th May 2024. See Notification of Entry onto Register‐ Certificate of Compliance on
Completion attached. RECEIVED: 16/06/2026
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The assessment of matters such as means of escape, travel distances, compartmentation, fire
detection and alarm systems, emergency lighting and other life‐safety measures properly falls
within the process outlined above.
Accordingly, the matters raised by the Planning Authority in relation to fire safety are being
addressed through the appropriate statutory certification process established for that
purpose. The present application concerns the planning merits of the retained works and the
planning considerations arising therefrom.
It is noted that the subject development for retention does not give rise to any measurable
additional material planning impacts in terms of servicing, occupancy or environmental
capacity.
FI Response Point 6
The information submitted is insufficient with regards environmental health and protection.
Accordingly, please submit updated certification from a qualified engineer confirming that the
wastewater treatment system approved under 20/155 has been installed as approved, is
operating to design standards, and would have sufficient capacity to cater for increased
occupancy levels. Loading calculations shall be based on actual occupancy, not hotel
occupancy.
Response
In response to the above, an updated report and certification prepared by Mitchell
Environmental Ltd. accompanies this Further Information submission.
The accompanying certification confirms that:
The wastewater treatment system approved under Planning Permission Ref. 20/155
has been installed and completed in accordance with the approved design;
The treatment system is operational and functioning in accordance with its design
parameters;
The treatment system was designed to accommodate a loading of 290 Population
Equivalent (PE);
Adequate treatment capacity exists to serve the retained development the subject of
this application.
The applicant notes that wastewater treatment systems are designed and assessed having
regard to occupancy levels and wastewater generation characteristics. In this regard, the RECEIVED: 16/06/2026
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relevant consideration is the loading placed upon the treatment system rather than the
category of occupants accommodated within the premises.
As confirmed by the accompanying engineering certification, the wastewater treatment
infrastructure serving the premises has adequate capacity to accommodate the retained
development.
Accordingly, no wastewater capacity, environmental health or environmental protection
concerns arise in relation to the works proposed for retention.
For completeness, it is noted that the accommodation of persons seeking international
protection within the premises has not resulted in any measurable additional material
environmental impacts when compared with the authorised hotel/guest accommodation use,
and the subject development can be accommodated within the capacity of the existing
wastewater treatment infrastructure.
FI Response Point 7
Objections to your application have been received, raising concerns primarily about the
continued use of the property as an IPAS/emergency accommodation centre rather than as a
commercial hotel. Issues cited include loss of a tourism asset and associated economic impact,
social isolation of residents due to the rural location, and inadequate access to services.
Additional points relate to compliance with fire safety and disability access standards,
potential environmental impacts, and the perception that granting retention would reward
non‐compliance and prevent a return to tourism use. Please review the planning file and
respond to each objection individually and the separate issues raised therein.
Response
The applicant acknowledges the observations received by the Planning Authority and has
reviewed the issues raised therein.
The observations raise a number of recurring themes which are addressed below.
(a) Loss of Tourism Accommodation
A number of submissions express concern regarding the continued use of the premises for
the accommodation of persons seeking International Protection rather than as a conventional
hotel. RECEIVED: 16/06/2026
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The applicant notes that the premises was originally developed and authorised as hotel/guest
accommodation and remains physically capable of operating in that manner. The retained
works, which comprise internal alterations and the provision of 9 additional bedrooms within
the existing building, do not prejudice the future use of the premises as hotel
accommodation.
As outlined elsewhere in this Further Information response, it was the applicant’s intention
at the time of Planning Ref. 20/155 that the premises would ret urn to conventional hotel use.
However, circumstances subsequently evolved and the premises has continued to assist in
meeting an ongoing State requirement for accommodation for people seeking international
protection. The retained works do not alter the physical suitability of the building for hotel
use and would not prevent a return to such use in the future. The retained works do not alter
the physical suitability of the premises for hotel use and would not prevent a return to such
use in the future should circumstances permit.
(b) Location and Access to Services
The premises is located on Kingscourt Road, Carrickmacross and benefits from established
transport arrangements linking the site with Carrickmacross town centre. A transport
timetable accompanies this Further Information response.
Carrickmacross provides a broad range of retail, educational, healthcare, recreational,
community and employment facilities. As outlined in response to Point 4 above, the premises
benefits from regular connectivity to these services and no transport, accessibility or road
safety concerns arise in relation to the retained works.
(c) Fire Safety and Disability Access
A Fire Safety & Disabled Access Certificate have been granted and a Certificate of Compliance
on Completion was submitted to Monaghan County Council on the 4th April 2024 for the
works granted under planning application 25‐155 and included the construction of the 9 no.
additional bedrooms which are the subject of this planning application. Monaghan County
Council placed these works on the Building Control Management System (BCMS) register on
the 20th May 2024. See Notification of Entry onto Register‐ Certificate of Compliance on
Completion attached.
Accordingly, the matters raised in relation to fire safety and accessibility have been addressed
through the appropriate certification procedures established for that purpose.
RECEIVED: 16/06/2026
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(d) Environmental Impact and Wastewater Capacity
An updated report and certification prepared by Mitchell Environmental Ltd. accompanies
this Further Information submission and confirms that the wastewater treatment system
approved under Planning Permission Ref. 20/155 has been installed in accordance with the
approved design, is operational and has adequate capacity to accommodate the retained
development.
No wastewater capacity, environmental health or environmental protection concerns arise in
relation to the works proposed for retention.
(e) Retention Permission and Compliance
The applicant acknowledges that certain internal alterations carried out within the building
differ from previously approved plans and, for that reason, the present retention application
has been submitted.
The Planning and Development Act 2000 (as amended) expressly provides for the submission
and assessment of retention applications. The purpose of the present application is to enable
the Planning Authority to assess the retained works on their planning merits having regard to
the proper planning and sustainable development of the area.
The fact that an application is made in retention form does not alter the statutory assessment
to be carried out by the Planning Authority, where no requirement for EIA is involved. The
High Court has held in the case of Kelly v An Bord Pleanala that the fact that the development
the subject matter of a retention application is unauthorised is not a relevant consideration
and, in that case, the Board were found to have acted ultra vires.
FI Response Point 8
“In the interest of clarity and to allow for a fully informed decision, please submit details
confirming that the development of the site to date is, where relevant, compliant with the
plans, documents and conditions of planning permission file numbers 20/155 and 17/155”.
Response
The applicant acknowledges the Planning Authority's request for clarification regarding
compliance with Planning Permissions Ref. 17/155 and Ref. 20/155. RECEIVED: 16/06/2026
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Having reviewed the development undertaken on site to date, the applicant is of the opinion
that the development is substantially compliant with the approved plans, particulars and
conditions attached to Planning Permissions Ref. 17/155 and Ref. 20/155, save for the internal
alterations and additional bedroom accommodation which form the subject matter of the
present retention application.
The purpose of the current application is to regularise those specific departures from the
previously approved plans and to enable the Planning Authority to assess the retained works
on their planning merits.
In relation to the wastewater treatment system, the applicant has submitted updated
certification from Mitchell Environmental Ltd. confirming that the treatment system
approved under Planning Permission Ref. 20/155 has been installed and completed in
accordance with the approved design, is operational and functioning within its design
parameters, and has adequate capacity to accommodate the retained development.
The applicant further notes that the waste facility permit/licensing process remains ongoing.
However, it is noted that the relevant condition does not expressly require that such licence
or permit be obtained prior to the commencement or occupation of the development. The
determination of that process is proceeding through the appropriate statutory mechanisms
and is separate to the planning assessment of the retained works the subject of this
application.
Accordingly, save for the matters specifically identified and addressed through the present
retention application, the applicant is not aware of any material departure from the approved
development which has been carried out under Planning Permissions Ref. 97/552, Ref. 17/155
and Ref. 20/155, nor have these developments been the subject of enforcement.
FI Response Point 9
“The Planning Authority notes that a Section 5 Declaration request (file number EX25/102) has
been submitted seeking confirmation that the change of use from hotel to accommodation for
protected persons constitutes exempted development. Further Information has already been
requested in relation to this declaration, and the matter remains unresolved. In the interest of
clarity and to allow for a fully informed decision, please submit:
(a) An update on the status of EX25/102, including any correspondence or documentation
submitted to date.
(b) A clear statement confirming whether the applicant maintains that the current use is
exempted development under Class 14 of the Planning and Development Regulations
2001 (as amended).
Same shall include supporting information demonstrating compliance with Article 9(1)
of the Planning and Development Regulations 2001 (as amended), specifically details RECEIVED: 16/06/2026
17
confirming that the development of the site to date is, where relevant, compliant with
the plans, documents and conditions of planning permission file numbers 20/155 and
17/155.
(c) Confirmation that the building is used to accommodate protected persons.
(d) Clarification on how the exempted development position relates to the current
application and whether the applicant intends to regularise the use through planning
permission or continue to rely on exempted development provisions.
Response
(a) Status of Section 5 Declaration Ref. EX25/102
The applicant confirms that a Section 5 Declaration request (Ref. EX25/102) has been
submitted to Monaghan County Council seeking a determination regarding the planning
status of the accommodation of persons seeking international protection within the premises.
The Planning Authority subsequently issued a request for Further Information in respect of
that declaration. At the date of this submission, the applicant has not responded to that
Further Information request and no determination has issued. Accordingly, the matter
remains pending.
(b) Applicant's Position
The applicant notes that a Section 5 Declaration request (Ref. EX25/102) remains under
consideration by Monaghan County Council and that no determination has issued.
The present application seeks retention permission for internal alterations and the provision
of 9 additional bedrooms within the existing building. As acknowledged in this application,
those works currently constitute unauthorised development pending determination of the
present retention application.
In these circumstances, the applicant considers that the planning status of the retained works
should first be clarified through the determination of the present application before a
definitive position is advanced in relation to the matters raised within Ref. EX25/102.
Accordingly, the applicant does not propose to duplicate or pre‐empt the ongoing Section 5
process through the present application. The applicant reserves its position in relation to the
applicability of any exempted development provisions pending determination of both the
present retention application and the Section 5 Declaration process. RECEIVED: 16/06/2026
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For completeness, the applicant confirms that the premises continues to operate as an
authorised accommodation building developed pursuant to Planning Permissions Ref.
97/552, Ref. 17/155 and Ref. 20/155 and refers the Planning Authority to the response
provided under Point 8 above regarding compliance with those permissions.
(c) Confirmation of Current Occupation
The applicant confirms that the premises is currently used to provide accommodation for
persons seeking international protection.
(d) Relationship Between EX25/102 and the Present Application
The present application relates solely to the retention of internal alterations and the provision
of 9 additional bedrooms within an existing authorised accommodation building.
The Section 5 Declaration process concerns the planning status of the current occupation of
the premises and raises separate legal and planning questions to those arising in the present
application.
While there is an interaction between the two processes, the type of assessment to be made
in relation to the present application is fundamentally different to that under section 5. The
applicant respectfully submits that the present application should be determined having
regard to the planning merits of the retained physical works and the planning impacts arising
therefrom.
The retained works are capable of serving either hotel/guest accommodation or
accommodation for persons seeking international protection and, as demonstrated
throughout this Further Information response, do not give rise to any measurable additional
material planning impacts in terms of transport, wastewater generation, servicing
requirements, environmental capacity or infrastructure demand.
The determination of the present application will assist in clarifying the factual and planning
context within which the outstanding issues arising under Ref. EX25/102 fall to be considered.
FI Response Point 10
RECEIVED: 16/06/2026
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The Core and Housing Strategies (see Sections 2.6 and 3.13) within the County Development
Plan 2025‐2031 seek to locate residential development in the population centres of existing
towns and villages where basic social and infrastructural services are available. In this regard,
the Planning Authority has fundamental concerns with the unsustainable nature of the
proposed development due to the scale, location, lack of associated services, and lack of
connectivity with existing services. Accordingly, in the interest of clarity and to allow for a fully
informed decision, please provide additional information to demonstrate how the proposed
development complies with the Core and Housing Strategies, including information on:
(a) How the continued use and proposed intensification of accommodation at this rural
location aligns with the Core Strategy principles of sustainable development and
settlement hierarchy.
(b) Measures to mitigate isolation and ensure access to essential services, transport, and
community facilities.
Supporting documentation should be provided where relevant.
Response
The applicant acknowledges the Planning Authority's concerns regarding the location of the
premises and the policies contained within the Core Strategy and Housing Strategy of the
Monaghan County Development Plan 2025–2031.
At the outset, it is important to note that the present application does not seek permission
for a new residential development, a new accommodation facility or the establishment of a
new settlement in the open countryside. The applicant also does not accept the
characterisation of the proposal as an "intensification" of development in the conventional
planning sense. Rather, the application relates to internal alterations and the retention of
additional bedrooms within an existing authorised accommodation building, with no material
expansion of the building footprint or alteration to the established use of the premises as an
accommodation facility.
The subject application relates solely to the retention of internal alterations and the provision
of 9 additional bedrooms within an existing authorised accommodation building. The
premises has existed in accommodation use for many years and benefits from an established
planning history, including Planning Permissions Ref. 17/155 and Ref. 20/155. RECEIVED: 16/06/2026
20
(a) Core Strategy and Settlement Hierarchy
The Core Strategy and Housing Strategy of the Development Plan are principally concerned
with the spatial distribution of population growth, housing delivery and the location of new
residential development within the settlement hierarchy.
The retained development the subject of this application does not constitute a new
residential development and does not result in the establishment of a new population centre
or expansion of an existing settlement.
The retained works comprise internal alterations and additional bedroom accommodation
within an existing authorised accommodation building. The works do not alter the overall
footprint of the development, do not extend the developed area of the site and do not
generate any requirement for additional public infrastructure beyond that already serving the
premises.
Accordingly, it is submitted that the retained development does not conflict with the
objectives of the Core Strategy or Housing Strategy and may be assessed on its own planning
merits having regard to the nature and scale of the works proposed.
(b) Access to Services and Mitigation of Isolation
The premises is located on Kingscourt Road, Carrickmacross and benefits from established
transport arrangements linking the site with Carrickmacross town centre.
As outlined in response to Point 4 above, a transport timetable accompanies this Further
Information response and demonstrates the availability of regular scheduled transport
services between the premises and Carrickmacross.
Carrickmacross provides a broad range of retail, educational, healthcare, community,
recreational and employment facilities. The transport arrangements currently serving the
premises facilitate access to these services and provide connectivity between the site and the
town centre throughout the day.
The applicant further notes that management arrangements, resident supports and
compliance with the 2019 National Standards for Accommodation Offered to People in the
Protection Process are subject to separate contractual and regulatory oversight by the
relevant State authorities.
The retained development comprises internal alterations and additional bedroom
accommodation within an existing authorised accommodation building. The proposal does RECEIVED: 16/06/2026
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not constitute a new residential development, does not undermine the settlement hierarchy
established under the Development Plan and does not give rise to any measurable additional
material planning impacts in terms of infrastructure, transport, environmental capacity or
service provision.
FI Response Point 11
The information submitted is insufficient with regards environmental protection. Accordingly,
the following is required:
(a) A revised site layout plan (1:500) demonstrating the following:
(i) All existing and proposed surface/storm water drainage systems (outlined in
blue).
(ii) The directional flow of all existing/proposed surface water pipelines.
(iii) Any SuDS measures.
(iv) All associated discharge points and outfalls.
(b) An appropriately completed water protection plan checklist.
Response
Please see attached information from Mitchell Environmental Ltd which addresses the above
in full.
I trust the above is in order and await hearing from you in due course. If you require further
clarification with regards to the above, please do not hesitate to contact me.
Kind Regards
________________
Ian Doyle,
Planning Consultant
BA (HONS) Town & Country Planning. BTP
RECEIVED: 16/06/2026