The report referred to in the Question would appear to have been a submission to the planning authority, in the context of the internal processes relating to the preparation of its draft development plan.
The documentation forwarded by planning authorities to my Department in the context of my statutory role as consultee in the development plan preparation process is confined to the written statement and maps and environmental reports, as provided for under Section 12 (1) (a) of the Planning and Development Act 2000 (as amended).
Therefore, my Department does not have sight of submissions and reports internal to the deliberative process undertaken by planning authorities in the context of the preparation of their development plans and accordingly, my Department would not have had sight of the document referred to in the question, prior to making its submission in relation to the draft County Donegal Development Plan 2018 - 2024.
My Department was emailed with a copy of the submission by a member of Donegal County Council on 10th November 2017 after my Department's observations were forwarded to the planning authority. However, my Department has no statutory role in commenting on submissions made on the development plan preparation process outside of the provisions under Section 12(1)(a) above.
In general terms, therefore, observations by my Department are made only in the context of the written statement and maps and environmental reports as prepared and adopted by the relevant planning authority for public consultation.
