If submission is made by an agent, normally the agent would indicate that they are making the submission on behalf of Mr./Mrs X, but I don't see where Regs require said agent to disclose such information. ANYBODY can make a submission, so effectively your agent could be making a submission in his/her own right. At the end of the day, an Aboriginee in the outback who has never been to Ireland can pay his €20 and make a valid submission in relation to any planning application in Ireland and that submisison is just as valid as a submisison from the applicant's next door neighbour.