Demolition of Building vs Earth Work

Is building demolition work constituted part of the earth work? This is question posted to me early yesterday morning. Presently, requirement for submitting earth work plan to the local authority requires that planning permission is still valid and in effect or else the project proponents have to extend the approval of planning permission first. Once work has started on site, then validity of planning permission is deem have complied with and other approvals by the Local Council such as earth work plan, building plan and road and drainage plan precede. Therefore, many project proponent will either forward application to extend the planning permission if work is anticipated to start before the approval of any of the above plans or to seek speedy approval of these plans before expiry of the planning permission. This is well understood thus far.

However, there is a project of involving demolition of an existing building and constructing the new building as replacement. The project proponent got the permit from the respective department to demolish the existing building before the expiry of planning permission but only managed to make submission for earth work plan approval well after the expiry of planning permission period. Under such circumstances, is demolition of existing building constituted as part of the earth work? If yes, then it means work has started without approval and is subjected to fine. But at the same time, it means planning permission is not required for extension. If the answer is no in which demolition work is not considered as part of the earth work, then the project proponent has to submit planning permission to extend the period of validity.

According to the Street, Drainage and Building Act, 1974 (Act 133), Section 70a, earth work includes any act to dig, flatten, fill with any material, piling, building foundation or to cut down the trees or other actions that affect or impact on any piece of land. So, the question now is whether the demolition work on existing building is construed as one type of earth work according to the above definition?

i am still looking for an answer.