DEC Officer Report

PLANNING OFFICER REPORT AND RECOMMENDATION

Application No.: 23/00280/B Applicant: Andreas Parish Commissioners Proposal: Re-site village play park to area currently known as Millennium Garden Site Address: Andreas Village Millennium Garden Andreas Village Isle Of Man IM7 4EZ Planning Officer: Mr Paul Visigah Photo Taken: 12.07.2023 Site Visit: 12.07.2023 Expected Decision Level: Planning Committee Recommended Decision: Permitted Date of Recommendation: 28.09.2023

Conditions and Notes for Approval

C : Conditions for approval N : Notes attached to conditions

• C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.

Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.

• C 2. Notwithstanding the details that have been submitted, the leylandii hedge bordering the eastern boundary of the site, the sod bank to the southern boundary of the site, and the hedge on the southwest section of the site, shall be retained as shown on the Proposed Illustrations 1 and 2, and as indicated in the Planning Statement, all received 24 August 2023. The boundary treatment shall be retained as such thereafter unless changes to the surrounding landscaping have been submitted to and approved in writing by the Department.

Reason: In the interests of protecting and enhancing the biodiversity of the environment, and to safeguard the appearance of the development and the surrounding area.

This application has been recommended for approval for the following reason.

Overall, it is considered that the proposal would comply with the provisions of General Policy 2, Transport Policies 1 and 4, and Environment Policy 5, whilst aligning broadly with the requirements of Environment Policy 4 of the Isle of Man Strategic Plan, the reasons set out in this report; having no significant impacts upon public or private amenities, highway safety or landscape impacts.

Plans/Drawings/Information;

This approval relates to the submitted documents and drawing received on 7 March 2023, and the Additional Documents and plans received 24 August 2023.

_______________________________________________________________ Interested Person Status – Additional Persons

None _____________________________________________________________________________

Officer’s Report

THIS APPLICATION IS REFERRED TO THE COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT.

0.0 PREAMBLE - 0.1 This application was originally on the agenda for 10th July 2023 and was deferred by the Planning Committee to enable the applicant's provide further information on the proposal. Since then, additional information has been received, and the report has been amended to reflect the additional details provided, with the assessment also amended to capture the new information.

1.0 THE APPLICATION SITE - 1.1 The application site which is currently identified as Millennium Garden sits to the west of the former Police Station at Andreas (now a dwelling), and has the Ayre United Football Club grounds enclosing its west and north boundaries. The site directly adjoins the A9 (Andreas Road) which runs along its southern boundary. - 1.2 The site frontage is characterised by the mature hedging which has a strong link in terms of visual connection with the other frontages west of the application site which are also characterised by mature landscaping. The site also has most of its boundary enclosed in mature landscaping comprising high hedges and some trees. The site is generally flat and measures 35.05m x 20.64m.

2.0 THE PROPOSAL - 2.1 The application seeks approval to Re-site village Play Park to area currently known as Millennium Garden. The scheme would see the relocation of the play park from its current location to the proposed site which forms part of the Sports field, all owned by the local authority and zoned for recreational purposes. - 2.2 The items of play equipment to be installed on site would include:

• a. Junior Multi-Play Unit (KPL301012-CUSTOM-20189465) with total height 376cm, and fall height 178cm.
• b. Toddler Multi-Play Unit (KPL101212-CUSTOM-20189466) with total height 214cm, and fall height 58cm
• c. Swing with Shell, Duo & Flat Seats (KSW904-CUSTOM-20189027) with total height 271cm, and fall height 145cm
• d. Swing with You & Me and Cradle Seats (KSW902-CUSTOM-20189028) with total height 271cm, and fall height 143cm
• e. Wheelchair Carousel (PCM157-0201) with total height 100cm, and fall height 70cm
• f. Daisy 4-Way Springer (KPL110-0411) with total height 65cm, and fall height 60cm
• g. Ladybird Springer (M16801-01P) with total height 79cm, and fall height 60cm
• h. Two Agora Steel Benches (PAR4150-0608) with total height 50cm

2.3 The site would be fenced internally in a 1.2m high galvanized Playspec Bow Top fencing which would be erected behind the hedges on the site boundary save for the northern

• boundary and northwest boundary of the site where hedges would be removed. The scheme would also involve the installation of a 1.2m high Prosafe Combi Pedestrian/Vehicle Gate, as well as a 1.2m High Prosafe Single Self-closing Gate installed along its perimeter. Grass mat safety surfacing would be laid over the grass areas on the site within an area measuring about 27.7m x 13.48m.
• 2.4 The scheme would retain the leylandii hedge bordering the east side of the site; the sod bank hedge to the southern boundary of the site, and the shrub hedgerow partly bordering the southwest side of the site, just by the entrance to the site. There are also 10 ornamental mature trees and shrubs within the site which would be retained. As has already been noted, the hedges and planting on the northern boundary and northwest boundary would be removed to allow views to the site from the surrounding sports field.

2.3 The applicants have provided a Planning Statement which states the following:

• o This site is included within the area known as the Sports field, all owned and maintained by the Local Authority and zoned for recreational purposes.
• o Whilst no change of use need be sought the Authority recognises the need to gain permission for the intended re-siting of the play park.
• o Some of the existing play equipment is now over 30 years old and well past its best. The Local Authority will organise fund raising to purchase new equipment to be installed in the new site, and preliminary work on this has already started. The existing play equipment would be removed and scrapped and the new equipment will include all-inclusive items for disabled access.
• o The garden area was extensively planted as a Millennium project but has since been reduced to an area of grass surrounded by overgrown shrubs and trees. Originally this was intended as an attractive area to sit with the surrounding landscaping but it has increasingly become an area where youngsters gather, vandalise any seating, and often cause a general nuisance, with the planted shrubbery giving cover from passing traffic, or people on the sports field. There is also costly maintenance involved for this small area which currently serves little purpose for the village.
• o The Commissioners wish to remove the overgrown shrubbery within the site to improve visibility and safety. Some of these bushes have extremely sharp leaves and would cause injury if anyone should fall into them and as such need to be removed.
• o The key reasons for the proposal are:

• - to improve visibility and make it a safe play area for children;
• - to increase the available area of the play park;
• - to remove risk of injury from briars and brambles; and
• - to remove potential risk of immediate cover for vermin.

• o An industry standard metal playground fence would be installed around the play equipment with 2 self-closing access gates. The fencing will be steel as recommended for use for play park areas, and this particular type of fencing has already been installed at the car park area of the Sports field so the same style/colour would be used to match this.
• o A report from Assistant Tree Officer/ DEFA states that there are 2 sycamore trees which could be removed from the site boundary with the road way (under licence), and these be replaced with birch or rowan within the area upon completion(identified in previous documents).
• o Play Park planners highly recommend that sites have clear 360 vision to provide safe play areas for children and this proposal will allow for this.

• o The proposed play park area will, in effect, revert to form part of the sports field (which this site was previously), with the recommended steel fencing in place surrounding the play equipment. As stated before, the proposed equipment includes all-inclusive items and the removal of the shrubs and overgrowth will create a natural flow from the Sports field to the play park for children and parents allowing for easy access, including disabled.
• o The 10 foot high leylandii hedge will remain between the nearest residence (The former Police House) and the gas tanks to provide privacy and, to some extent, a sound barrier; the 3 foot high (approx.) sod hedge along the roadside will maintain the continuous green corridor; as will the bush hedging at one of the entrances to the site (west side).
• o The trees/shrubs to be retained are ornamental and now mature so are unlikely to grow and dominate the park, as is the over-riding problem with the existing play park.
• o All the vegetation being retained can be easily maintained which is also an important consideration to ensure the safety of the site.
• o Finally, as pointed out in previous statements from the Commissioners, there is already approval in place for a further 31 houses in the village and a condition of this scheme requires suitable recreational facilities for all children. The Commissioners are very aware that the current facilities (which have no provision for disabilities) are inadequate and are keen to
• obtain permission for this project in order to commence work.

- 3.0 PLANNING POLICY

3.1 In terms of local plan policy, the application site is within an area zoned as "Residential" identified on the 1982 Development Plan (north), and the site is not within a Conservation Area. The site is not susceptible to flood risk, there are no registered trees on site, and the site is not within a Registered Tree Area.

3.2 In terms of strategic plan policy, the Isle of Man Strategic Plan contains the following policies which are considered to be specifically material to the assessment of this current planning application: - 3.3 General Policy 2: Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development:

• (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them;
• (c) does not affect adversely the character of the surrounding landscape or townscape;
• (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;

• (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks;
• (g) does not affect adversely the amenity of local residents or the character of the locality;
• (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space;

3.4 Recreation Policy 4: Open Space must be provided on site or conveniently close to the development which it is intended to serve, and should be easily accessible by foot and public transport. - 3.5 Design of public open space

• 3.5.1 Paragraph A.6.9 "Both formal and informal open space should be designed as an integral part of the development so that it offers recreational value and visual relief and in some cases may

provide the main focal point of the development. There is often local opposition to the provision of children's play spaces especially within new residential developments. Therefore it is essential that facilities be designed as part of a comprehensive approach to estate layout, which includes consideration of good neighbourliness, the need for adequate privacy and amenity for the occupiers of dwellings, road traffic and pedestrian activity and community safety. The following are also important considerations in the siting and layout of public open space which should:-

• o be defensible but not sited to cause a nuisance to dwellings;
• o easily maintainable;
• o be of sufficient size to be usable;
• o build upon existing linkages to provide green corridors;
• o incorporate existing landscape features;
• o provide appropriate children's play equipment in areas from which dogs are excluded, preferably by the use of fencing and dog proof grids, and
• o be of a design and layout to enable future adoption and maintenance by the Local Authority"

3.6 Section 10.3: Open Space "10.3.1 The presence and use of various forms of Open Space in towns and villages on the Island form an integral part of the fabric of community life. Open Space takes various forms and serves many purposes. It ranges from formally laid parks to the wide and extensive public footpath network including Raad Ny Foillan and Millennium Way.

• 10.3.2 Open Space forms part of our heritage as well as being an attractive and usable asset, and, in the wider context, provides visual and spiritual relief from the developed urban settlements on the Island. In addition, it provides recreational enjoyment in respect of various active and some less active forms of sporting activity. Open Spaces also provide a means of improving the health and fitness of the Island's population. Open Space is defined in this context as land used for recreational purposes, both formal and informal, including amenity space whether privately or publicly owned.
• 10.3.3 The Strategic Plan needs to facilitate sport and recreation opportunities and to ensure that areas of open space are retained, and provided to meet local needs. The Strategic Plan will facilitate this by a three pronged approach: a) protecting existing assets; b) making good deficiencies in existing provision; and c) providing adequate provision within new development. In pursuing these three objectives, it is recognised that developers will not be expected to make good existing deficiencies in recreational facilities as a requirement of carrying out their developments.
• 10.3.4 To ensure that suitable provision is made for sport and recreation development across the Island it is proposed that Area Plans should incorporate an assessment of sport and recreation need and provisions. This should include, where appropriate water-based sport and recreation. Such assessments should recognise that sport and recreation facilities may benefit local communities across defined Area Plan boundaries."

3.7 Environment Policy 4 protects biodiversity (including protected species and designated sites). - 3.8 Transport Policy 1: New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes. - 3.9 Transport Policy 4: The new and existing highways which serve any new development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan.

- 4.0 OTHER MATERIAL PLANNING CONSIDERATIONS

- 4.1 IOM BIODIVERSITY STRATEGY 2015 TO 2025

• 4.1.1 The strategic aims (In part):

• o Managing biodiversity changes to minimise loss of species and habitats.
• o Maintaining, restoring and enhancing native biodiversity, where necessary.

• 4.1.2 Habitat loss actions "21. DEFA will continue to promote a policy of 'no net loss' for semi-natural Manx habitats and species and ensure that unavoidable loss is replaced or effectively compensated for."
• 5.0 PLANNING HISTORY

5.1 The application site has been the subject of a previous planning application which is considered relevant to the current application. Planning approval was granted for Erection of timber shelter fence for Millennium Scented Garden, in East corner of Andreas Sportsfield under PA 98/01130/B in November 1998. The current scheme seeks to remove this garden (including plantings) and replace it with the proposed play park. - 6.0 REPRESENTATIONS Copies of representations received can be viewed on the government's website. This report contains summaries only.

6.1 Representation from the Department of Infrastructure (DOI) Highways Division confirms that they find the proposal to have no significant negative impact upon highway safety, network functionality and /or parking (17 March 2023).

• 6.1.1 Following review of revised/additional plans and information provided by the applicants, DOI Highways have stated that they do not oppose the proposals (5 September 2023).

6.2 DEFA Ecosystem Policy Team have made the following comments on the application (30 March 2023):

• o They do not believe that there is currently enough information submitted with this application.
• o They note that the Planning statement makes reference to the fact that the Commissioners intend to remove the existing shrubbery from the area, but have not provided information about how they intent to mitigate their ecological impacts.
• o They note that a siting of equipment plan has been provided, but this seem to indicate that the park equipment will fit within the grass area and that there will be no need for shrub removal or removal will be limited. So the plans to remove all of the shrubbery seem unnecessary.
• o The state that an updated plan should be provided which accurately show the plans for the park in relation to the shrubbery, as well as a plan showing where replaced shrub planting is to be undertaken. If the intention is to replace the current park with this new park, then we believe the old park should be utilised for this shrub planting.
• o They state that they understand that problems have arisen in regards to abuse of the Millennium garden area, and that the current shrub planting gives cover for this, but believe that replacement planting could be undertaken in such a way to not enable this antisocial behaviour in the future.
• o They state that without a scheme to provide for replacement planting, the application would be contrary to Strategic Policy 4 (b) of the Isle of Man Strategic Plan which states that Proposals for Development must 'protect or enhance the nature conservation and landscape quality of urban as well as rural areas'.

• 6.2.1 In view of the comments made by the DEFA Ecosystem Policy Team, the applicants have submitted a revised Planning Statement to clearly articulate the scheme, whilst making changes to elements of the proposal. Likewise, additional plans and photos have been submitted to provide further clarity to the proposals.

• 6.2.2 Having reviewed the additional/amended documents and plans submitted by the applicants, the DEFA Ecosystem Policy Team have sent in revised comments which details the following (18 August 2023):

• o They appreciate all of the additionally information provided and note that it helps to clarify the situation.
• o They state that their understanding now is that the boundary vegetation is mostly to be retained but reduced in height and trimmed back for safety reasons.
• o They state that they are content with what is being proposed, as it doesn't involve the total removal of boundary vegetation, just its trimming back.
• o They request that boundary trimming is undertaken outside of the nesting bird season (March - August inclusive).
• o They request that a condition is secured for boundary hedging and the sod bank to be retained but trimmed back in line with the visuals provided.

6.3 Andreas Parish Commissioners has not commented at the time of writing this report, although they were consulted on 13 March 2023. - 6.4 No comments have been received from neighbouring properties.

- 7.0 ASSESSMENT

7.1 The fundamental issues to consider in the assessment and determination of this application are:

• i. The principle of development;
• ii. The potential impact upon the visual amenities of the area;
• iii. The potential impact upon neighbouring amenities;
• iv. The Impacts on highway safety, and
• v. Ecological Impacts.

7.2 The Principle (GP2, Section 10.3, & RP 4)

• 7.2.1 In assessing the principle of the proposed development it is considered that the site is within an area zoned for residential use, although it is noted that the site currently serves a public garden which falls for classification as a public open space. The site also adjoins an area that largely serves as a sports, recreation and open space, thus, the proposed use of the site as a play parks which is a public open space for children would be compatible with the dominant adjoining uses.
• 7.2.2 As well, the site is within close proximity to the surrounding residential areas and school serving the locality, a situation that would align with the requirements of Recreation Policy 4 which requires that Open Space must be provided on site or conveniently close to the development which it is intended to serve, and should be easily accessible by foot and public transport.
• 7.2.3 Additionally, the site is defensible but not sited so close to existing dwellings that it would cause a nuisance to dwellings, is of a size and at a location that it would be easily maintainable, is of sufficient size to be usable given that it would easily accommodate the required play equipment for children, would provide appropriate children's play equipment in an area that is fenced to enable child safety, is linked to existing green corridors in the area, and is owned by the Local Authority which would carry out its regular maintenance.
• 7.2.4 It is also important to note that the proposal would facilitate sport and recreation opportunities for children, would ensure that areas of open space are retained and provided to meet the local needs of the Andreas community, ensure existing play assets are protected, whilst making good deficiencies in existing play provisions as is currently the case with the existing play park which now has most its facilities in a moribund state. As well, the new facility would make adequate provision for new play equipment within the new development, thus compensating for the gaps in terms of provisions of the previous facility. Therefore, it is

considered that the principle of the development is acceptable and well-aligned with the goals of Recreation Policy 4, General Policy 2, and Section 10.3 of the Strategic Plan.

7.3 Visual Impact (GP2)

• 7.3.1 As referenced earlier in this report, General Policy 2 (c and f) of the Strategic Plan requires that development should not affect adversely the character of the surrounding landscape and that new development should incorporate where possible existing topography and landscape features, particularly trees and sod banks. In this case, it is considered that the site frontage as existing is largely characterised by the mature hedging, with a break only created by the existing accesses along the road. This feature is also evident on the opposite side of the road where there is a continuation of mature hedging and sod banks, only broken up by existing accesses. Therefore, it is considered that the proposal to retain the hedging/sodbank on the east, south and part west boundary would serve to preserve the character of this part of Andreas defined by the mature landscaping that line the main thoroughfare.
• 7.3.2 Whilst the removal of the existing mature landscaping which screens the northern sections of the site from the adjoining sports ground and replacement with a 1.2m high galvanized bow top fencing would make the alterations particularly apparent when viewed from the A17 (Bride Road) which adjoins north-western section of the football ground, it is not judged that this would be averse to the character of this part of the sports ground as the sites situated southwest of the application site already have hard boundary treatments which the fencing on the proposed play park would form a connection with. As such, it is not considered that this element of the proposal would have an adverse visual impact when viewed from Bride Road.

7.4 Impact on neighbouring amenity (GP2)

• 7.4.1 With regard to impacts on neighbouring amenity, it is considered that the nearest property to the application site is the former Police Station which sits east of the site and situated about 9.6m away, with the potential for increased noise impacts from the proposed development. However, the applicants have indicated that the existing mature hedging which sits on the boundary of the proposed play area would be retained to serve as a sound buffer. Besides, it is not unusual to have play areas next to residential uses as both uses are complimentary. As such, it is not considered that any impacts in terms of noise generated would be sufficient to warrant refusal of the scheme.
• 7.4.2 It is also important to note that the area is currently being used as an open space with the adjoining uses also identified for supporting sports and leisure activities for a varied range of age groups, including children of different ages. Therefore, it is not considered that any impacts in terms of noise generated, as well as the scope and intensity of activities being carried out would be considerably increased over that currently attainable at the site and surrounding sports and recreation areas.
• 7.4.3 Based on the foregoing, it is not considered the proposal will result in significant impacts on neighbouring amenity over that which is currently attainable at the site and area.

7.5 Highway safety Impacts (GP2, TP1 & TP4)

• 7.5.1 In assessing the impacts on highway safety (including parking), it is considered that the site would still benefit from the existing parking provisions in the area which currently serve the existing play park and sports grounds. The site is also well-connected to existing pedestrian routes within Andreas, which would ensure that the proposal adequately caters for visitors who walk or cycle and this would be in line with the requirements of general Policy 2 (h & i) and Transport Policy 1.
• 7.5.2 The proposal has also been assessed by Highway Services who have considered the scheme and have no objection. Besides, the use of the play equipment within the play park

would be in conjunction with the adjoining sports and recreation uses, and as such the scheme is unlikely to generate a large traffic volumes considerably above that attracted by the existing uses of the broader site area.

7.6 Impacts on Biodiversity (GP2 & EP4)

• 7.6.1 In terms of impacts on biodiversity, it is considered that the scheme would result in the removal some of the existing mature landscaping on site, on the northern and part western section of the site boundary, with potential to result in some loss of biodiversity. The ecosystem team in reviewing the proposal had indicated that they would prefer to see all the hedges and sodbank retained and trimmed, although the applicants have raised concerns with child safety which would mean that retaining all of the sodbank and hedges would not be in the interest of the users of the site (children). On balance, it is considered that allowance can be made for the removal of some of the hedging on the grounds that most of the plantings and mature trees within the previous play area would be retained, thus providing some mitigation for the loss at the application site.
• 7.6.2 It would be vital to note that a key reasons for the relocation of the lay area, is to ensure that the development of the previous play park would not result in adverse impacts on the existing trees on site which were planned to be removed to improve the amenities of the site as a play area. Hence, it is considered that any loss of biodiversity at the current site would be compensated by the retention of the mature plantings and trees at the play park. The fact that there are plans to register some of the trees at the previous play park would also serve to facilitate habitat establishment at the previous site, given that the trees would be protected and largely undisturbed.
• 7.6.3 Notwithstanding the factors that have been raised in Paragraph 7.6.2 above which identifies some form of mitigation for habitat loss at the application site, the retained sodbank and hedging would be secured by a condition to ensure that they are retained in the interest of preserving the biodiversity of the site. Moreover, the Ecosystem Policy Team have also indicated that they do not oppose the scheme. It is, therefore, considered that the scheme as propose would be broadly aligned to the requirements of Environment Policies 4 and 5 of the Strategic Plan.

- 8.0 CONCLUSION

8.1 The fact that there is a clear justification for the proposal to ensure the continuous provision of a vital play area for children within the locality is noted, particularly as the existing play park is no longer fit for purpose (as has been articulated in the applicant's submissions),and this weighs in favour of the scheme. The retention of the roadside hedging which serves to contribute to the character of the area is also judged to result in positive impacts on the visual amenities of the street scene and landscape character.

8.2 The removal of part of the surrounding mature landscaping around the site boundary would result in some adverse impacts. However, as the previous play park site would have the mature trees and mature landscaping preserved to protect the surrounding trees, with a significant proportion of the existing mature landscaping around the application site also retained, it is not considered that any impacts resulting from the proposed development would be sufficient to warrant refusal of the scheme.

8.3 Overall, it is, considered that the scheme would broadly align with the requirements Environment Policy 4, whilst complying with the provisions of General Policy 2, Transport Policies 1 and 4, and Environment Policy 5 of the IOM Strategic Plan. Accordingly, it is recommended that the application be approved. - 9.0 INTERESTED PERSON STATUS

9.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:

• (a) the applicant (including an agent acting on their behalf);
• (b) any Government Department that has made written representations that the Department considers material;
• (c) the Highways Division of the Department of Infrastructure;
• (d) Manx National Heritage where it has made written representations that the Department considers material;
• (e) Manx Utilities where it has made written representations that the Department considers material;
• (f) the local authority in whose district the land the subject of the application is situated; and
• (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material.

9.2 The decision maker must determine:

• o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and
• o whether there are other persons to those listed above who should be given Interested Person Status

9.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status.

I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to that body by the appropriate DEFA Delegation and that in making this decision the Committee has agreed the recommendation in relation to who should be afforded Interested Person Status.

Decision Made : Permitted Committee Meeting Date: 16.10.2023

Signed : P VISIGAH Presenting Officer

Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report).

Signatory to delete as appropriate YES/NO See below Customer note This copy of the officer report reflects the content of the file copy and has been produced in this form for the benefit of our online services/customers and archive records.