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Application No.: 20/00175/B Applicant: Mrs Julia Diggines Proposal: Change of use of land to create a camp site, creation of hard standing for camping vehicles with associated electric hook up points, installation of cladding to and relocation of existing toilet / wash facilities and erection of an attached motorcycle shelter, relocation of a wooden structure to provide a café and social area and construction of decking Site Address: Fields 234227 & 234228 Glebe Farm Main Road Kirk Michael Isle Of Man Planning Officer: Miss Lucy Kinrade Expected Decision Level: Officer Delegation Recommended Decision: Refused Date of Recommendation: 16.06.2020 _________________________________________________________________ Reasons for Refusal R : Reasons for Refusal O : Notes attached to reasons - R 1. No information has been provided to demonstrate that there are no other reasonably acceptable alternative sites or that there is an overriding national need for a campsite of this standard in this specific location. The proposal would result in an unacceptable and unwarranted loss of agricultural land without suitable justification contrary to Environment Policy 1 and General Policy 3 which seek to protect the countryside for its own sake and would present a substandard facility contrary to the principles of the Department for Enterprise IOM Destination Management Plan 2016-2020 and Non-Serviced Accommodation Futures Study (March 2017). - R 2. The development would result in a significant culmination and spread of camping items, campervans and vehicles on land which is not designated for development and which would adversely impact the visual appearance of the site, the countryside and the surrounding AHLV contrary to Environment Policy 2. - R 3. The development would result in a significant culmination and spread of camping items, campervans and vehicles on land which is not designated for development and which would adversely impact the visual appearance of the site and detracting from the historic and architectural quality of the adjacent and surrounding Conservation Area contrary to Environment Policy 35. - R 4. It has not been fully demonstrated that the proposal and the expected increase in traffic at the site can be suitably accommodated without detriment or harm to the highway safety of the area contrary to Transport Policy 4. - R 5. By reason of the unacceptable loss of an agricultural site without overriding need or alternatives being demonstrated, the subsequent adverse visual impacts on the immediate surrounding environment and the lack of evidence to truly demonstrate highway safety the proposal is contrary to Strategic Policy 8. _______________________________________________________________
It is recommended that the owners/occupiers of the following properties should be given Interested Person Status as they are considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
The application requires an EIA subject to Appendix 5 of the Strategic Plan and they are considered to satisfy all of the requirements of paragraph 2 of the Department's Operational Policy on Interested Person Status (July 2020).
It is recommended that the owners/occupiers of the following properties should not be given Interested Person Status as they are not considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
Officer’s Report THE SITE
1.1 The application site comprises fields 234227 and 234228 situated on the outskirts of Kirk Michael between the existing petrol station and the junction with Orrisdale Road. The site sits between the A3 main road and the Old Railway Line, to the south of the site is an existing stable building forming part of the previous Pennybridge Stables equestrian facility. The site forms part of a larger land holding belonging to Glebe Farm the majority of which sits on the other side of the Old Railway Line. - 1.2 To the rear of the existing stable building is a detached structures providing toilet and shower facilities for a temporary campsite for TT and race periods approved under PA's 14/01001/B and 18/00993/C, this approved campsite area sitting alongside the existing stable building and to the rear of an existing triangular copse of trees, access provided via the existing track onto the Orrisdale Road. - 1.3 The application is provided with photographs showing another structure within the existing stables building which is currently used as a café and kitchen area for the campsite, although no planning history can be found for this structure. PROPOSAL
2.1 Proposed are a number of works to facilitate a change of use to an all year round camping facility. - 2.2 The works proposed include an increase to the camping area to include the full extent of both field's 234227 and 234228, the creation hardstanding to provide camper vehicle parking and hook up points along the edge nearest the Old Railway Line, the relocation of the existing café building from within the stables to the rear of the stable building, the erection of a lean-to covered canopy and installation of timber cladding to the existing toilet and shower facilities and the creation of a timber deck area above the existing soakaway. - 2.3 The application is provided with supporting information including a site plan setting out the positions of the existing, relocated and proposed structures, a drawing for the proposed lean-to canopy area, the proposed camping areas, the position of the 4 vehicle hook up points and a supporting statement including photographs of the site and the existing wc/shower facilities and a photograph of the access and hardstanding from the Orrisdale Road. PLANNING HISTORY
3.1 Part of the site has been subject to two previous applications considered to be materially relevant to this application.
4.1 The site lies within an area designated as 'Open Space (agriculture)' on the Kirk Michael Local Plan 1994. Part of the site (behind the existing stables) also sits within the Kirk Michael Conservation Area 2006. The site is also recognised as being an Area of High Landscape Value and Scenic Significance on the 1982 Development Plan.
4.2 There is a presumption against development here as set out in General Policy 3 and Environment Policies 1 and 2 of the Isle of Man Strategic Plan 2016 and there shall be no lesser constraints placed upon tourism-related development than on any other forms of development in undesignated areas (Business Policy 11), however tourist proposals will generally be permitted where they make use of existing building of interest and quality and where they do not affect adversely environmental, agricultural, or highway interests and enable enjoyment of our local attractions (Strategic Policy 8).
4.3 Environment Policy 1 seeks to protect the countryside for its own sake unless development is considered to be of over-riding national need and no other alternatives sites available. General Policy 3 sets out a number of exceptions to development in the countryside such as agricultural buildings, replacement dwelling and previously developed land but does not include campsites, and Environment Policy 2 applies two tests in the protection of landscape character ensuring development does not harm the character and quality of the landscape, and that its location is essential. Development which does not preserve or enhance the character and appearance of the Conservation Area would also contravene Environment Policy 35. - 4.4 It is recognised that camping is becoming an important part of the Island's tourist attractions and an increasing popular form of tourist accommodation, and growth of employment opportunities will also be encouraged (Business Policy 1) so long as they accord with planning policy. While there are no formal sites identified for camping use on northern or western local plans there are a number of existing campsites in this area of the Island including Glen Wyllin and Cronk Aashen in Kirk Michael, Ballamoar in Ballaugh, 'The Claddaghs' in Sulby, 'Silly Moos' in Lezayre, and Peel Campsite and Knockaloe Beg in Peel. In addition to which there are two further tourist sites at Sunset Lakes (Peel) and Glen Helen which provide higher end tourist lodges. Flora and fauna habitats are expected across rural and undeveloped sites
4.5 New development across the Island should, where possible, be located close to existing infrastructure and transport routes and be designed as to suitably accommodate pedestrian and vehicular movements without compromising highway safety (Transport Policies 1 and 4). Developments which are likely to have a significant effect on the surrounding environment are also required to provide an Environmental Impact Assessment and suitable supporting information (Environment Policy 24) which assesses the likely environmental effects of a proposal. Appendix 5 of the Strategic Plan lists the types of development that require an EIA in every case; this includes permanent campsites and caravan sites. - 4.6 In 2017 a study was prepared by 'Hotel Solutions' on behalf of the Department for Enterprise providing an evidence base from which areas of potential action and focus could be highlighted in helping to deliver the IOM Destination Management Plan 2016-2020 (DMP). The Isle of Man Non-Serviced Accommodation Futures Study (March 2017) (NSA) is available on request from DfE, it shall be a material consideration in the assessment of the current application along with the DMP. The NSA report research sets out potential for different types of non-serviced accommodation on the Island, the potential for campsites is as follows: "Campsites
REPRESENTATIONS Copies of representations received can be viewed on the Government's website. This report contains summaries only.
5.1 Kirk Michael Commissioners - Objection (15/04/2020) - the road and entrance would not be able to cope with the added traffic and would be dangerous egress onto a busy main road causing issue for vehicles and pedestrians. The land is also agricultural, while there is no issue for temporary use during TT and MGP there is danger of this becoming a full time camper van park. The village already has perfectly adequate campsite at Glen Wyllin and would not be willing to provide a licence for another especially one causing accidents onto the main road.
5.2 Department of Infrastructure Highway Services - Do not oppose (28/02/2020)
5.3 DEFA Ecosystems Policy Officer - Comments (16/03/2020) summarised as:
5.4 The owners of Ballachree, Church Town, Lezayre - (30/03/2020) also the owners of Ballarhennie Farm, Orrisdale Road which is situated adjacent to the application site. Objections summarised as follows:
5.5 The owners of Ballarhennie Beg Cottage (05/04/2020) - Objection - there are traffic flow management issues in the area of the Main A3 main road and the Orrisdale Road which runs the perimeter of the proposed site, extensive letters of concern have been sent to both DOI and to the local Commissioners in respect of these issues. - 5.6 The owners of Ballarhenny, Orrisdale Road - Objection (27/04/2020 and 27/05/2020) concern is expressed in relation to the increased level of traffic as a result of the proposal which would exacerbate the traffic issues already experience in Kirk Michael. The Orrisdale loop Road is also a concealed entrance from the A3. The proposal would put pressure on sewage management and it I questioned whether the capacity of the existing system is suitable for the increased use by a permanent campsite. The proposal unless shielded from the road would be an eyesore, and it is questioned why a second campsite in Kirk Michael is required. The land is zoned as agricultural use only on the Kirk Michael Local Plan 1994 and this has not changed to date, the proposal contravenes this land use designation. Increase pedestrian stiles would damage the sod banking. It is questioned whether DOI Highway Services have undertaken a site visit the proposed access is far from adequate due to the parking area, Milly's Memorial Garden and the layout of the road being a blind bend made worse if cars are parking in the layby area. The yellow notice was obscured by gorse and preventing many from seeing it. - 5.7 The owners of Kilimani, Orrisdale Loop Road (05/06/2020) - there are already traffic issues in the area and the proposal would exacerbate this, while the applicant considers vehicles will only be moving on entry and exit of stay it's likely that visitors will take vehicles out exploring the Island. The Orrisdale loop road contains sharp bends and is an unrestricted road where vehicles can travel at speed with disregard to walkers, residents or animals. - 5.8 Representative of Ballarhennie Farm c/o 79 Parliament Street Ramsey (10/06/2020) advise that they have been appointed by the owner of Ballarhennie Farm to act on behalf of their objections. - 5.9 The owner of Faaie ny Cabbal - Objection (12/06/2020) - concerns regarding the safety of the Orrisdale loop road and junction on to A3, traffic is usually light and locals only but significant increases around TT/MGP and visitors are not as familiar with the highway safety issues as the locals - mirrors could help with visibility. The land is zoned for agriculture and parked vehicles would cause visual impact. Capacity of sewers should be checked and tested as there have been previous instance of raw sewage in immediate environment, the stiles highlighted as providing access only provide access to the grass bank for watching racing with no flat access to the public pavement.
5.11 The applicant further sought to respond to comments raised and provide an environmental assessment (13/05/2020), summarised as follows:
6.1 Tourism development shall only be supported where it complies with the relevant planning policies of the Strategic Plan and any proposal on land not designated for development such is the case here first needs to fully demonstrate that there are no other alternatives available (such as alternative sites) and that the proposal is of sufficient national need as to outweigh the tests of those policies which seek to protect the Islands countryside from unnecessary and unwarranted development (EP1 and GP3). Should the principle of development be considered acceptable, the test would then fall to the environmental impacts of the development (EP24), whether there would be any visual impacts on the streetscene, the AHLV or Conservation Area (EP2 and EP35), the amenity impacts on neighbouring properties and land uses and whether there would be any impacts in terms of highway safety (TP1 and TP4) or on local habitats and general ecology (EP4). Principle (GP3 and EP1)
6.2 Part of the site nearest the existing stable building has approval as a temporary campsite for race periods which is typical for a number of temporary campsites across the Island not only in providing an alternative source of income through diversification but also to
help accommodate the significant tourist numbers visiting the Island at a time when permanent campsites are likely operating at or near full capacity. Many of these temporary campsites also make best use of existing sites that not available for their normal use during race periods such as football and rugby pitches or the inability to use agricultural fields such as this case with bikes and noise temporarily impacting horse grazing and the riding school.
6.3 Now the proposal is for a larger camp site with additional campervan facilities and on a permanent all year round basis. The exceptional basis on which the previous temporary applications were considered now carries very little weight as the scheme steps outside of those times where bike noise impacted the usability of the site. The proposal therefore needs to evidence the specific national need for the proposed campsite and in this specific location. - 6.4 The application contains no information as to what other sites have been considered and or discounted as part of the design process and it is therefore unknown if there would be any other alternatives sites more appropriate for the proposed development. - 6.5 Other than enquiry demand from prospective visitors both off and on Island as set out in the supporting statement, the application contains no information in terms of the previous uptake or demand of the temporary facility and there are no facts or figures of a business plan to demonstrate economic benefit as to outweigh any adverse impacts on economic, social or environment sustainability as set out in the Draft PPS on the Economy 2012 in delivering prosperity, jobs, diversification and economic growth across the Island. - 6.6 The Destination Management Plan study states; "Growing the walking, cycling, mountain biking, Enduro riding and motorbiking holiday and break market on the Island will require existing and new non-serviced accommodation businesses to provide facilities such as drying rooms, boot and bike wash facilities, and secure cycle and motorbike storage.", in addition to this the later produced Non-Serviced Accommodation study (NSA) specifies the potential for new 4 or 5 star campsites although the more sensible route to pursue being the upgrade of existing campsites and possibly their extension into adjacent land, with provision being made in the south where camping sites are lacking. - 6.7 The current proposal is in the north and seek to offers some of the listed features such as a café, cooking area, electric hook ups and motorbike store although their quality could be argued given the basic structures in which they are contained. The site does not however appear to offer any laundry or drying rooms, children's play space, Wi-Fi, combined camper and tent space or heated toilet and shower facilities, items which would contribute to achieving a 4 or 5 star high quality facility. - 6.8 The proposed campsite offers a limited range of the facilities outlined in the NSA in trying to upgrade the quality of the Islands campsites, there is no demonstrable economic benefit and the standard as shown within the application is not sufficient enough to warrant the campsite being of such exceptional quality or overriding national need as to outweigh the test of the policies. Environmental Impact (EP24) - 6.9 Appendix 5 of the Strategic Plan 2016 makes reference to the types of applications that require an Environmental Impact Assessment including permanent campsites, and until such a time that a Planning Policy Statement (PPS) is prepared specifying the manner in which the Department intends to deal with these applications they are to be considered against the UK Town and Country Planning (Environmental Impact Assessment) Regulations 2017. Schedule 2 of these Regulations states that a permanent campsite or caravan sites that exceed 1 hectare must provide an EIA, the current site measures 1.56hectares. The application has been provide with an environmental report that purports to be an EIA and therefore accords with Environment Policy 24 and Appendix 5 of the Strategic Plan 2016.
and at the height of camping season, with many gathering to socialise and enjoy the outdoors, often with camping there can be music and BBQ's, most reasonable people are sympathetic to their neighbours and surroundings and generally act in good behaviour, however this cannot be guaranteed at all times. The supporting statement indicates that there will be staff on site, this may help to discourage any antisocial or unacceptable behaviour particularly at unsocial hours.
6.14 Coming and goings to the site will increase, although there is already a level of activity in the area through the existing petrol station and convenience shop, the equestrian stables and riding school (although this use appears to have ceased recently) and with the site being on an main route with high volumes of passing traffic, it may be that additional comings and goings as a result may not be so extreme as to cause any new or significant amenity harm on the surrounding residents as to warrant a refusal. Highway Safety (TP1 and TP4) - 6.15 Access into and out of the site is via an existing gate on to the Orrisdale Road, the site is in close proximity and can make use of existing infrastructure and footpaths. Representations have highlighted that the hardstanding onto which this access gate opens before joining with the Orrisdale Road is not in ownership of the applicant and the hardstanding area provides off road parking for members of the community who use the public footpaths or the adjoining picnic area. - 6.16 While DOI Highway Services have not opposed the application subject to conditions, there remains a planning concerns for the lack of information and detail provided as part of the application as to demonstrated that the existing access can cope with the demand expected from the campsite and that the levels of traffic which are to come and go from the site. There is no information as to traffic surveys, parking surveys of the lay by, no information as to the visibility achievable from the proposed access nor from the Orrisdale Road junction on to the
7.1 While the site bounds an existing village and is positioned as to make best use of existing infrastructure, there is no information provided as to demonstrate that there are no other reasonably acceptable alternatives or that there is an overriding national need for a campsite of this standard in this specific location. It is therefore considered that the proposal would be contrary to the policies within the Strategic Plan which seek to protect the countryside for its own sake (Environment Policy 1 and General Policy 3) and contrary to the principles of the Department for Enterprise IOM Destination Management Plan 2016-2020 and Non-Serviced Accommodation Futures Study (March 2017).
7.2 The development would result in a significant culmination and spread of camping items, campervans and vehicles on land which is not designated for development and which would adversely impact the visual appearance of the site, the countryside and the surrounding AHLV. The culmination of camping paraphernalia would also detract from the historic and architectural quality of the adjacent and surrounding Conservation Area (Environment Policy 2 and Environment Policy 35).
7.3 It has not been demonstrated that the proposed use and the expected increase in traffic at the site can be suitably accommodated without detriment to the highway safety of the area or to satisfy the significant concerns raised by local residents and the Local Commissioners. In this respect the proposal is considered contrary to those policies seeking to maintain safe and suitable highway access for all users (Transport Policy 4). - 7.4 Some environmental impacts have been covered in the EIA with many relying on onsite maintenance and management in order to limit adverse impact such as noise, waste, lighting and ecology. However by reason of the unacceptable loss of an agricultural site without overriding need or alternatives being demonstrated, the subsequent visual impact on the immediate surrounding environment and the lack of evidence to truly demonstrate highway safety the proposal is considered to fail Strategic Policy 8.
8.1 By virtue of the Town and Country Planning (Development Procedure) (No 2) Order 2013 (Article 6(4), the following persons are automatically interested persons:
8.2 The Planning Committee must determine:
8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status.
I can confirm that this decision has been made by a Principal Planner in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation.
Decision Made : Refused Date: 17.06.2020 Determining officer
Signed : S CORLETT Sarah Corlett Principal Planner
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