The applicant, in his submissions, said that no decision could be looked at in isolation and that the decision at issue here was in the context of the "corrupt processing" of the relevant forestry licence application. He referred to various alleged actions of named staff members of the Department's forestry service and said that these were all material issues of fact. More specifically in relation to the statement of reasons, the applicant described it as "a fantasy", and "not based on any fact, any Forest Service Reports, or on-site information. It is a complete fabrication". He said that the statement of reasons was based on a telephone conversation on or around 10 June 2021 between two named persons neither of whom had been on the relevant site or had any knowledge of it. He disputed the specific facts contained in the statement of reasons including the reference to calcium, to lime deposits, and to the description of the exotic trees as being mainly spruce. He said that alluvial woodland is rare and a protected habitat that is defined by flooding, and that this is why the water protection measures would be required. In support of this, he referred to other reports and assessments which he said contained recommendations for such water protection measures.
