These are the points that I think I would be most interested in, if I were one of the people on the adjudicating panel.
1. IANAL, but I assume that the responsibilities of those on the panel are to approve applications that are within the law and best practice, and reject those that are contrary to law or fail to maintain acceptable practices. Note that there is a little bit of a grey area in the middle. A panel that rejected a proper application would be doing a disservice to the public, and likely lay itself open to legal application from an aggrieved applicant. Similarly, an inappropriate granting of a licence could open the body to legal action from the opposing parties. To that extent, the adjudication is a box-ticking exercise, but absolutely not a token exercise; the issues must be determined and / or judged with full and proper facts.
2. On the face of it, there are some boxes that are ticked that support the application, albeit with some caveats, and there are some serious objections. Since the biggest problems in the application appear to be the objections, there must be a proper review of those objections.
On to the uh meat of the application ...
3. The application is in the name for Fripps Farm CIC. I would be asking for guidance from the council's legal officer / lawyers as to how to separate the suitability requirements of the business and the person. For example, The business operates from a residential dwelling. Is this correct? If, for example, animals "owned" by the CIC are kept inside the residence, this would imply that the continuing operation of the business depends upon access to the residence. If the residence is used for the CIC, then the check boxes in the application must be tested against the entire properteee. If the business operates away and entirely separately from the residence, then suitability requirements wouldn't entirely cover the residence (except perhaps for things such as fire break between house and business). But it certainly looks like the residence is a part of the business operation, in which case questions about employee access to business areas in the residence in the event of JM's absence become relevant. In addition, training plans, operational plans and the ability to provide animal welfare around the clock are critical.
4. What business plan does the CIC have to support the current animals and those proposed in the DAW application? What plan is there for a lack of income, to cover the business being wound up, taking into consideration employee / redundancy / proper disposal / dispersion of the animals? For how long can the business run without income; how much time would it need to rehome the animals safely in such an event, and does the business maintain reserves to cover this?
5. If the current noise complaints are subject to an ongoing investigation, I could not envisage granting the application. There is prima facie evidence that the complaints are valid, and if any consideration cannot be entirely objective, because decibel readings don't tell the entire story, the objections speak for themselves.
6. What is the truth of the allegations concerning escaped animals in the past? What remedial action, if any, has been taken to prevent repeat episodes?
7. How many animals are currently held at Fripps Farm and what records does the business have regarding upkeep and welfare of the animals currently there?
8. What plans does the business have to vary the number of animals kept at this location? What is the appropriate maximum number of animals that the business has determined to be appropriate, for the sake of animal welfare, and for the sake of concerned third parties, ie neighbours, environment etc?
9. In the light of the objections, and caveats raised in the boxes that have been ticked, I would consider it wise not to grant any application until after the improvements had been made (and of course even then only in the event of all objections being quashed). ie the increase in size of the enclosure, and contraceptive measures of the animals, before and not after the granting of any licence.
10. The inability of the panel to contact the existing owner is a red flag. The application should not be granted so long as this line of communication is being withheld.
11. What is the legal status of the animal enclosures regarding building / planning regulations and any covenants?
12. What outstanding investigations are there that relate to the CIC and JM?
I assume that if she has the opportunity to do so, she'll pipe up at the meeting and complain that the objectors are all VJBs that dislike her. The objections do state that neighbours were welcoming to begin with, until her activities turned their lives upside down. I'd certainly like to make the point that it doesn't matter if the objectors are vile, or jellus, or bullies; any neighbour, be they a person of high or low character, has a right to object on the facts. And facts / nuisances described speak for themselves.
For those that missed it, there is a paragraph in the Agenda that says that exceptionally (due to the forthcoming General Election), that the meeting will not be broadcast online ... but a recording will be made available after the election.