Officer Report

PLANNING OFFICER REPORT AND RECOMMENDATIONS

Applicant: Silly Moos Campsite Limited Proposal Change of use of land to create a camp site with associated access tracks, hard standings, motorhome and tent pitches, reception and temporary communal facilities Site Address Field 124689 West Kimmeragh Road Bride Isle Of Man IM7 4BB Case Officer : Paul Visigah Photo Taken: 09.10.2024 Site Visit: 09.10.2024 Expected Decision Level Planning Committee Recommended Decision: Permitted Date of Recommendation 07.03.2025

Conditions and Notes for Approval

C : Conditions for approval N : Notes attached to conditions

• C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.

Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.

• C 2. This approval relates to the use of the area edged red and shown for camping pitches, and for a maximum of 12 motorhome pitches and 60 standard grass tent pitches within the site during the approved period of operation.

Reason: To ensure proper control of the development and to reflect the information provided in the application, as the Department has assessed the impact of the proposal on the basis of the specific use and the documents submitted. The dwelling is within an area not zoned for development and permission has been granted as an exception.

• C 3. The caravans/motorhomes stationed on the site shall not be occupied as a person's sole or main place of residence.

Reason: To ensure that the approved holiday accommodation is not used for permanent residential occupation.

• C 4. The temporary structures hereby approved shall be erected no sooner than 7 days before the first designated practice, and shall be removed no later than 7 days after the final race, of any of the following events:

• o Isle of Man TT; and

• o Manx Grand Prix. The accommodation on the site hereby approved (including any motorhome or tent) shall be
• occupied no sooner than 3 days before the first designated practice, and shall be removed no later than 3 days after the final race, of any of the following events:
• o Isle of Man TT; and
• o Manx Grand Prix.

Reason: To ensure proper control of the development and to reflect the information provided in the application, as the Department has assessed the impact of the proposal on the basis of the specific use and the documents submitted.

• C 5. Prior to the commencement of the development hereby approved, details of the landscaping to be carried out on site and along the boundary shall be submitted to and approved in writing by the Department. The detailed landscape plan shall include:

• o A detailed landscaping layout
• o Details of planting (no non-native species)
• o Site levels
• o Details of the landscape features (hedges and trees) marked to be retained on site The details of planting shall include:
• o Planting plans (at a scale not less than 1:100)
• o Written specification of planting and cultivation works to be undertaken
• o Schedules of plants, noting species, plant sizes, and proposed numbers/densities
• o A programme for the implementation, completion, and subsequent management of the proposed landscaping

The development shall be carried out in accordance with the approved scheme and shall be retained as such thereafter unless changes to the landscaping have been submitted to and approved in writing by the Department. Any additional removal must be compensated for by replacement planting in accordance with details which have first been approved in writing by the Department.

Reason: To ensure the site is appropriately landscaped, enhancing its appearance and providing environmental benefits.

• C 6. Prior to the commencement of the development hereby approved, details of a habitat management plan shall be submitted to and approved in writing by the Department. This plan shall include details of protection zones for existing hedgerow, Sodbanks and mature landscaping on the boundaries of the site, including physical barriers to ensure that camping activities do not encroach into these protection zones. This protection zones shall be implemented and shall be maintained throughout the period of use of the field for camping purposes in accordance with the approved details. The land shall thereafter be managed in full compliance with the approved habitat management plan for the lifetime of the development.

Reason: To safeguard the existing trees, sodbanks, hedgerows, and planting to be retained within the site and along the site boundary.

• C 7. No external lighting shall be installed on the site unless a sensitive low-level lighting plan has been submitted to and approved in writing by the Department. The lighting plan must adhere to the best practice guidance detailed in the Bat Conservation Trust and Institute of Lighting Professionals Guidance Note 8/23 on Bats and Artificial Lighting (2023). All external lighting shall be installed and operated strictly in accordance with the approved lighting plan.

• Reason: To avoid adverse ecological impacts on nocturnal wildlife, particularly bats, and to ensure that external lighting does not negatively affect the surrounding biodiversity.
• C 8. Prior to the commencement of the development hereby approved, a detailed waste management plan must be submitted to and approved in writing by the Department. The plan should outline measures for waste reduction, recycling, and disposal during both construction and operational phases of the development. The development shall not be carried out other than in accordance with this plan.

Reason: To ensure the development operates in an environmentally responsible manner and minimizes waste impact.

• C 9. The temporary structures, including marquees, must be fully removed during nonoperational periods. No external storage of camping-related materials, movable structures, or equipment shall take place outwith the permanent building/retained structures shown on the approved plan (Drawing No. 002 - Proposed Site Plan) on the site at any time outside of operational months detailed in Condition 4 of this approval.

Reason: To maintain the rural and agricultural character of the site during non-camping periods.

• C 10. A traffic and access management plan, outlining measures to manage vehicle movements and avoid congestion during peak periods (e.g., TT and MGP events), must be submitted and approved before the commencement of operations. Reason: To minimize the impact of additional traffic on nearby properties and road users.
• C 11. Prior to the commencement of the development hereby approved, parking areas shall be laid out in accordance with details which have first been approved in writing by the Department, and retained as such thereafter. The details shall include the dimensions, surface materials, and markings for designated spaces.

Reason: To ensure the parking areas are efficiently designed and provide safe and adequate capacity for visitors.

• C 12. The development hereby permitted shall not commence until details of the entrance and exit points, including measures to prevent surface water runoff onto the public highway, have been submitted to and approved in writing by the Department. These details shall include measures for seasonal access management to prevent unauthorized use of the site. The approved measures shall be implemented in full prior to the first use of the development and shall be maintained thereafter.

Reason: To prevent surface water runoff from the development from discharging onto the public highway, to avoid potential hazards to road users, and to preserve the integrity of the highway infrastructure.

• C 13. In the event that the development ceases to operate for a period exceeding 18 months, the approved building, all structures and hardstanding areas shall be removed, and the land shall be restored to its original state suitable for farming. A restoration plan detailing the steps to be taken to achieve this shall be submitted to and approved in writing by the Department within one month of the cessation of operations. The approved restoration plan shall be implemented in full within three months of its approval.

Reason: To ensure that the land is returned to a condition suitable for agricultural use, thereby preserving the agricultural potential of the site and preventing dereliction.

This application has been recommended for approval for the following reason. On balance, it is concluded that the proposal would not have significant adverse effects on public or private amenities, site ecology, highway safety, or landscape character. The development integrates camping-related infrastructure in a way that respects the character of the site and its surroundings, while also providing sufficient environmental information to address its permanent use.

The scheme ensures that the expected increase in traffic can be accommodated effectively, without compromising parking or highway safety. Additionally, the 65-meter separation distance from the nearest dwelling and the presence of mature landscaping help to protect residential amenity.

The proposal is, therefore, considered to comply with the requirements of Strategic Policy 8, Transport Policy 4, Environment Policies 1 and 24, and General Policy 3 of the IOM Strategic Plan 2016. It also aligns with the principles outlined in the Department for Enterprise IOM Destination Management Plan 2016-2020 and the Policy on the Development of Non-Serviced Accommodation 2019.

Plans/Drawings/Information; This approval relates to the following documents and plans:

• 1. Correspondence from the Applicants' Agent:

• o 4 March 2025
• o 13 January 2025

• 2. Economic Statement (3 March 2025)
• 3. 20 January 2025: o Transport Assessment prepared by Highway Mann Transport Consultants and dated

January 2025. o Design Statement prepared by Cornerstone Architects Ltd and dated January 2025.

• 4. 23 December 2024: o Ecological Assessment prepared by Curragh Environmental Consultancy and dated

December 2024.

• 5. 11 September 2024:

• o Cover Letter
• o Drw. 100 - Proposed Reception Plan and Elevations
• o Drw. 101 - Existing Portakabin Plans and Elevations
• o Drw. 001 - Site and Location
• o Drw. 002 - Proposed Site Plan _______________________________________________________________

Right to Appeal

It is recommended that the following organisations should be given the Right to Appeal on the basis that they have submitted relevant objections:

• o DOI - No objection subject to conditions which have not been applied. It is recommended that the following organisations should NOT be given the Right to Appeal:
• o Isle of Man Visit Agency - No objections.

It is recommended that the owners/occupiers of the following properties should be given the Right to Appeal as they have submitted an objection that meets the specified criteria:

• o Boayl Chirrym, West Kimmeragh Road - Objection ________________________________________________________________

Officer’s Report

THIS APPLICATION IS REFERRED TO THE PLANNING COMMITTEE AS THE PROPOSAL COULD BE CONSIDERED CONTRARY TO THE DEVELOPMENT PLAN BUT RECOMMENDED FOR APPROVAL

1.0 SITE - 1.1 The application site comprises Field 124689, West Kimmeragh Road, Bride 114108, which is an area of land located to the southern side of West Kimmeragh Road, and opposite the junctions between Thurot Cottage Road and West Kimmeragh Road. - 1.2 The site sits directly northwest of the dwelling Boayl Chirrym, which also sits south of West Kimmeragh Road. The land sits north of the Andreas Airfield, separated by an unsurfaced road which provides access to the application field and other sites in the area. There is a gated access onto this track from West Kimmeragh Road and directly opposite the junction. - 1.3 The site, enclosed with post and wire fencing, is currently utilized as an agricultural field for cattle rearing. Spanning approximately 9.51 acres, it was once part of the RAF Andreas airfield. The site consists of grassland with gorse surrounding the former RAF buildings and blast pens. - 1.4 The site boundaries consist of a sod hedge topped with gorse, combining to a height of approximately 2 metres on most parts of the site perimeter.

2.0 PROPOSAL - 2.1 The application seeks approval for Change of use of land to create a camp site with associated access tracks, hard standings, motorhome and tent pitches, reception, and temporary communal facilities. - 2.2 The proposed development would provide for:

• 1. Motorhome Pitches: 12 proposed motorhome pitches comprising permeable hardstanding.
• 2. Tent Pitches: 60 standard grass tent pitches.
• 3. Permanent Building: 6m x 6m shed proposed to serve as the reception for the campsite. Ridge height: approximately 3m above the external ground level.
• 4. Portakabin Type Buildings to serve as shower and toilet blocks, drying room, and catering facilities.
• 5. Temporary Marquee: this is to be erected during the operating periods at TT and MGP. Dimensions: 75ft x 60ft (approximately 22.86 meters by 18.29 meters).

2.3 The applicants specify that the motorhome and tent pitches will be exclusively for tourism and leisure use during the TT and MGP operating periods. Paved and grassy pathways have been utilized to ensure buildings, recreation areas, and maintenance facilities are accessible to all. The applicants have provided additional information regarding the times of opening as follows:

• 2.3.1 2025 TT Period:

• 1. Operating dates: 26th May to 7th June (inclusive).
• 2. Temporary campsite requirements: 19th May 2025 to 13th June (inclusive).

• 2.3.2 2025 MGP Period:

• 1. Operating dates: 17th August to 29th August (inclusive).
• 2. Temporary campsite requirements: 11th August to 6th September (inclusive).
• 2.3.3 The applicants highlight that these arrangements cater to early arrivals on the less frequent Irish ferries and also provide for late departures during each festival. They further clarify that all other periods during the year are NOT covered by this application.

2.4 The applicant has provided the following additional information in Correspondence dated

14 February 2025 regarding the operation of the site:

• 1. The description of the application is to be changed from a temporary to a permanent camping facility to address the matter of returning the field to agricultural status during periods of non-use. This will allow the applicant to remove the camping activities and maintain the access tracks during periods when the campsite is not used.
• 2. The applicants have stated that the proposed change pertains to a matter of feature rather than function, in order to reinforce the mode of operation of the campsite.

2.5 The following additional documents have been provided in support of the application:

• 1. Ecological Assessment prepared by Curragh Environmental Consultancy and dated December 2024.
• 2. Transport Assessment prepared by Highway Mann Transport Consultants and dated January 2025.
• 3. Design Statement prepared by Cornerstone Architects Ltd and dated January 2025.

2.6 Regarding the management of effluent from the site, the applicants have stated in their correspondence dated 13 January 2025 that the treated effluent from the site is to be collected in a tanker, which is to be emptied three times per week. This arrangement would ensure that there is no discharge into either the watercourse or the drainage field, addressing the concerns raised by DEFA EPU. They have also updated the drawing schedule to reflect this detail and included a note about effluent management in the revised design statement to provide further clarity and demonstrate compliance with relevant standards.

- 3.0 PLANNING POLICY

3.1 Site Specific:

• 3.1.1 The site lies within an area that is not zoned or designated for development under the adopted Isle of Man Development Plan Order 1982. The site is not within a Conservation Area or Area of high Landscape or Costal Value and Scenic Significance. The site is also not prone to Flood risks, or within a registered tree area, and there are no registered trees on site.

3.2 National: STRATEGIC PLAN (2016)

• 3.2.1 In planning terms, there is no specific policy provision within the Strategic Plan to support camp sites, and as such campsites which are a form of tourist development are treated the same as any other form of development in the countryside, given that the Strategic Plan stipulates a general presumption against development in areas which are not designated for development, and where the protection of the countryside is of paramount importance (EP 1 and GP3).

• 3.2.2 Relevant strategic Plan Policies:

• a. General Policy 3 - presumption against development outside allocated sites, other than specific exceptions.
• b. General Policy 2 - 'Development Control' considerations.
• c. Strategic Policy 1 - Efficient use of land and resources.
• d. Strategic Policy 3 - Development to safeguard character of existing towns and villages.
• e. Strategic Policies 4 and 5 relate to preserving the character of the landscape, preventing unacceptable environmental disturbance, and making positive contributions to the environment of the Island.

• f. Strategic Policy 8: Tourist development proposals will generally be permitted where they make use of existing built fabric of interest and quality, where they do not affect adversely environmental, agricultural, or highway interests and where they enable enjoyment of our natural and man-made attractions.
• g. Environment Policy 1 - Protection of the countryside and its ecology.
• h. Environment Policy 2 - Protection of Areas of High Landscape or Coastal Value and Scenic Significance.
• i. Environment Policy 4 and 5 protects ecology (including protected species and designated sites).
• j. Environment Policy 14 - Seeks to prevent the permanent loss of important and versatile agricultural land (Classes 1-2).
• k. Environment Policy 22 - pollution.
• l. Environment Policy 24 - requires that development which is likely to have a significant effect on the environment will be required to be accompanied by an EIA in certain cases or suitable supporting environmental information in all other cases. The cases that must have an EIA are stipulated in Appendix 5.
• m. Transport Policy 4 - Highway safety.
• n. Transport Policy 7 and Appendix A.7.6 - Parking Provisions.
• o. Community Policy 7 - Designing out criminal and anti-social behaviour.
• p. Community Policy 10 - Proper access for firefighting appliances
• q. Community Policy 11 - Prevention for the outbreak and spread of fire.
• r. Business Policy 1: The growth of employment opportunities throughout the Island will be encouraged provided that development proposals accord with the policies of this Plan.
• s. Business Policy 11: Tourism development must be in accordance with the sustainable development objectives of this plan; policies and designations which seek to protect the countryside from development will be applied to tourist development with as much weight as they are to other types of development.
• t. Business Policy 14: Tourism development may be permitted in rural areas provided that it complies with the policies in the Plan.
• u. Paragraph 9.5.3: The text emphasizes the importance of the Island's unique historical landscape, culture, and heritage as key attractions for tourists. It notes that while many tourist activities, like the TT Races, require minimal permanent development, there is still a need for built structures such as holiday accommodations. It considers that it is crucial to balance tourism needs with the protection of these assets and ensure that tourism development is sustainable. The text also highlights that tourism development should adhere to the same stringent policies as other types of development, whilst noting that larger projects may require an environmental impact assessment before receiving planning permission.

3.3 Area: AREA PLAN FOR THE NORTH AND WEST

• 3.3.1 It must be noted that at the time of writing, the Draft Area Plan for the North and West is not formally adopted and is only, at this stage, a broad direction of how planning policy is reviewing the areas. Their proposals can still be challenged at a public enquiry where an inspector could reach a different opinion to the drafts. The final draft would also need to be ratified by COMIN. This means that the 1982 development plan remains the correct land use designation, and no material weight is given to the Draft Area Plan for the North and West.
• 4.0 OTHER MATERIAL CONSIDERATIONS

4.1 Policy on the Development of Non-Serviced Accommodation 2019.

• 4.1.1 This document is an offshoot of the Isle of Man Non-Serviced Accommodation Futures Final Report (2017). It sets out governments priorities as it relates to tourism, provides a summary of the non-serviced study, whilst also outlining the current visitor economy strategy, in addition to articulating the Island Policy towards tourism development.

4.2 Isle of Man Visitor Economy Strategy 2022-2032

• 4.2.1 The Strategy's headline targets are to grow the annual visitor numbers to 500,000 by 2032 and increase the annual economic contribution of the Island's Visitor Economy to £520m. This will mean attracting an additional 170,500 visitors per year compared to 2019. The aim is to triple the holiday and short break market as well as grow all of the other visitor markets. Combined with an expected increase in average spending per visitor, driven by strong growth in longer staying and higher spending leisure markets, these visitor numbers should result in a more than doubling of annual visitor spending on the Island to £310m, which will support an increase in Visitor Economy jobs to 5,000 and generate an annual Exchequer benefit of £49m.

• 4.2.2 Programme 3: Visitor Accommodation Transformation A key aspiration is to widen our non-serviced accommodation supply with the introduction of the innovative offers that are finding a strong market in competitor destinations, such as backto-nature retreats, lifestyle and wellness resorts, sea cabins, treehouses, sky huts and luxury glamping sites.

4.3 Planning Policy Statement (PPS): Planning & the Economy (A Consultation Document February 2012)

• 4.3.1 "In applying the provisions of the Strategic and Area Plans, particularly General Policy 1 and General Policy 3 of the Strategic Plan, the Department will seek proposals to be supported by evidence that demonstrates that the proposed development would secure sustainable, long term economic growth of Island wide benefit, which meets the wider objectives of sustainable development by weighing market and other economic matters alongside environmental and social costs and benefits."
• 4.3.2 As this is not an adopted policy document, it is of limited weight.

4.4 IOM Biodiversity Strategy 2015 to 2025

• 4.4.1 The Strategy seeks to manage biodiversity changes to minimise loss of species and habitats, whilst seeking to maintain, restore and enhance native biodiversity, where necessary. Section 21 deals with Habitat loss actions through promoting a policy of 'no net loss' for seminatural Manx habitats and species and to ensure that unavoidable loss is replaced or effectively compensated for.
• 5.0 PLANNING HISTORY

5.1 An application which sought Approval in principle for the erection of a manufacturing plant for the processing and packaging of medical foods including R & D and administration facilities at the field and adjoining fields under PA 05/01190/A was withdrawn on 19 December 2005. - 6.0 REPRESENTATIONS Copies of representations received can be viewed on the Government's website. This report contains summaries only.

6.1 DOI Highways have made the following comments on the application (12 February 2025): o They advise that the proposal raises no significant road safety or highway network efficiency issues. Accordingly, they raise no objection to the proposal subject to conditions to address the following:

• - Visitor information packs to be distributed to each pitch booking upon arrival, outlining the public transport options available both daytime and evening with details on how to use (with particular regard to Connect bus service), options for taxi services, and details on the proposed shuttle bus service to be operated by the applicants.
• - Pedestrian route information and wayfinding to be provided to all visitors through the above packs and placed around the site directing all those going to Andreas on foot to go via the former airfield internal road joining Oatlands Road rather than along the A17.

6.2 DOI Highways Drainage Comments (16 September 2024):

• o They state that allowing surface water runoff onto a public highway contravenes Section 58 of the Highway Act 1986 and the guidance in section 11.3.11 of the Manual for Manx Roads.
• o They state that the application lacks details regarding the entrance and exit points, and request that the applicant should demonstrates compliance with the aforementioned clause.

6.3 DEFA EPU Comments (9 October 2024):

• o They state that the applicant or agent should provide further information on the discharge route for foul water effluent, as the application form indicates a connection to a new sewage treatment plant but lacks details on the discharge route.
• o They state that if the sewage treatment works are connected to a drainage ditch or watercourse, a discharge licence will be required, and further information, including the application form, is available here.
• o They state that if the discharge is connected to a soak-away, percolation tests must be carried out in compliance with Building Regulations. A discharge licence will not be required if the percolation tests are satisfactory and a full soak-away is installed.

• 6.3.1 In response to this request, the applicants have provided additional information in their correspondence dated 13 January 2025 (and published for re-consultation on 20 January 2025). The details are stated in Paragraph 2.7 of this report.
• 6.3.2 Since the additional discharge information was re-advertised, no further comments have been received from DEFA EPU.

6.4 DEFA Biodiversity Comments (DEFA Ecosystem Policy Team) - 24 December 2024:

• o No objection, subject to conditions.
• o They confirm that the Curragh Environmental Consultancy's (CEC) Ecological Assessment (December 2024) is comprehensive and meets required standards. The application will result in the loss of semi-improved grassland and scrub habitat, likely used by nesting birds. To mitigate this and comply with Strategic Policy 4 of the Isle of Man Strategic Plan 2016, they recommend replacement scrub and hedge planting as well as a habitat management plan.
• o Potential Conditions:

• - A soft landscaping plan must be approved in writing by Planning, with planting undertaken accordingly and replacement required for any lost or damaged plants within the first five years.
• - A habitat management plan must be submitted to and approved by Planning, with land managed as per the plan.
• - No external lighting to be installed unless a sensitive low-level lighting plan (as per Bat Conservation Trust and Institute of Lighting Professionals Guidance Note 8/23) is submitted and approved in writing.

• o They provide an advisory regarding nesting birds and vegetation removal on site.

6.5 Isle of Man Visit Agency Comments (27 September 2024):

• o The Visit Agency highlights the importance of temporary accommodation in addressing the Island's growing demand during events like the TT, given the insufficiency of permanent tourist accommodation.
• o They reference the Our Island Our Future Visitor Accommodation Transformation Strategy 2022-2032, which aims to deliver 1,000 new or upgraded accommodation units (500 serviced and 500 eco-friendly non-serviced) to support visitor growth over the next decade.
• o They note that the TT Strategy targets a peak visitor profile of 28,000 post-COVID, which is nearly five times the existing tourism accommodation capacity, emphasizing the need for additional temporary accommodations.
• o Silly Moos is acknowledged as an established operation, continuously registered as a campsite from 2012 until the closure of its previous site in 2023, aligning with strategic
• objectives. o For these reasons, the Visit Agency expresses full support for the application.

6.6 Comments from the Owners/Occupiers of Boayl Chirrym, West Kimmeragh Road (28 October 2024):

• o They object to the application, highlighting the impact of 72 pitches on noise, emissions, and frequent vehicle movements, including motorcycles, potentially operating 24 hours a day during TT and MGP periods.
• o They note safety concerns due to the site's remote location, lack of nearby public transport, and dangerous road conditions for pedestrians on the A17, necessitating visitor reliance on private transport and increasing traffic and emissions.
• o They raise concerns about queuing at the site entrance, speeding on nearby roads, and fast-moving heavy vehicles from nearby aggregate works.
• o They dispute the claim that the site qualifies as previously developed land, noting its long-term agricultural use and its semi-improved status, which they argue contributes to biodiversity and warrants preservation.
• o They argue that the development is not compliant with Policy 1 (c) of the IOM Strategic Plan 2016, which requires that sites utilize existing and planned infrastructure, facilities, and services.
• o They contend that Policy 8 is not relevant to this application as it does not align with its aims to avoid adverse environmental, agricultural, or highway impacts. Instead, they cite paragraph 4.4.5, which imposes restrictions on new development outside defined zones and highlights criteria they feel are not met by this proposal.
• o They express concerns about the lack of sight of critical reports requested by DOI and DEFA, such as the transport report and the Preliminary Ecological Appraisal (PEA).
• o They seek clarity on how services, including sewage, electricity, water, and internet, will be provided, noting potential impacts on their property.
• o They object to the permanent siting of toilet and shower blocks, arguing that it undermines the temporary nature of the proposed tourist site and is visually incompatible with the rural landscape.
• o They highlight the risk of a permanent site designation enabling future changes or extensions of use by other operators, regardless of the applicant's experience and good intentions. Requested Conditions (if approved):
• o The site must reflect its temporary nature by the removal of infrastructure post-events and reinstatement prior to subsequent events.
• o The site size should exclude the area directly adjacent to their property, particularly the triangular portion of land, to address concerns about immediate impacts and potential future expansion.
• o A reduced number of pitches should be considered.
• o Clarity should be obtained and agreed upon by all parties regarding sewage, electricity, water, and internet provisions, with detailed implementation plans for environmentally sustainable design principles.
• o Pollution monitoring should be carried out periodically to assess potential health impacts.

- 7.0 ASSESSMENT

7.1 The fundamental issues to consider with the current application are:

• 1. The principle of the proposed development.
• 2. The visual impact of the proposed campsite.
• 3. Environmental impacts.
• 4. Amenity Impacts.
• 5. Impacts on Biodiversity,
• 6. Impact on Parking and Highway safety, and
• 7. Loss of agricultural land.

7.2 THE PRINCIPLE (GP3, EP1, BP 11, Strategic Policy 8 & Paragraph 9.5.3 of the Strategic Plan)

• 7.2.1 The Strategic Plan, Strategic Policy 8 sets out a broad approach that 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).

• 7.2.2 The detailed Strategic Plan policies regarding tourist development emphasize permanent built structures. They outline that tourism development on land not designated for development, such as in this application, must first provide sufficient justification for the proposed development. While the Strategic Plan makes limited references to camping, it does provide some support, particularly in paragraph 9.5.3, which highlights the economic benefits and minimal permanent development associated with camping. It is further recognised that camping is becoming an important part of the Island's tourist attractions and an increasing popular form of tourist accommodation, and the Department of Enterprise is supportive of initiatives which attract and accommodate more visitors to and on the Island. The broader policy support from more recent non-planning strategies is also noted.
• 7.2.3 Camping has become an increasingly significant element of the Island's tourism appeal, as supported by recent approvals of various campsites, including those integrated into rural areas. While the Strategic Plan does not specifically support the reception of new structures to support tourism development, it does promote the use of existing buildings (EP16) and includes broader support for camping facilities (Paragraph 9.5.3). These policies underline camping's contribution to tourism without necessitating significant permanent developments.
• 7.2.4 The current proposal aligns with these principles. While including some permanent structures, the design minimizes their footprint. The only permanent structure is a modest reception shed (6m x 6m, with a ridge height of 3m), while other buildings such as shower and toilet blocks, a drying room, and catering facilities, are Portakabin-style, easily removable structures. Additionally, temporary infrastructure for events like TT and MGP, including a marquee, enhances site flexibility. Permanent access infrastructure, such as roads and footpaths, ensures functionality while having minimal impacts on then broad appearance of the site as viewed from the surrounding area.
• 7.2.5 To justify the proposal, the applicants conducted a search for alternative sites over a year, selecting this location based on its accessibility, and as it would be easily integrated with the landscape. Positioned in an agricultural setting, the site also supports rural tourism activities like hiking while maintaining proximity to nature. Furthermore, the proposed seasonal use (five months annually) ensures compatibility with ongoing agricultural activities, promoting sustainability.
• 7.2.6 This scheme aligns with both the Strategic Plan's Business Policy 13 and the Isle of Man Visitor Economy Strategy 2022-2032, which prioritize diverse visitor accommodation. By extending services beyond TT and MGP seasons, the campsite addresses the national need for flexible accommodation options, including motorhome stopovers, while adhering to objectives outlined in the Policy on the Development of Non-Serviced Accommodation 2019.
• 7.2.7 Operationally, the scheme will create employment opportunities, including four part-time staff during the camping period and contractors for site maintenance. Furthermore, it will stimulate the local economy through visitor spending at nearby businesses, such as local stores, pubs, and eateries. During peak periods (e.g., TT and MGP events), the economic benefits are significant, with estimated general spending and revenues amounting to at least £711,256, excluding off-season contributions. Silly Moos also fosters community engagement through discounted rates for Marshalls during the festivals. This proposal reflects strategic goals across economic, social, and environmental dimensions, demonstrating its long-term viability and substantial contribution to both local and national interests.

• 7.2.8 While the retention of the access road hardstanding would preclude the full-scale use of the site for farming during non-camping periods, the proposal ensures that most features and structures would be removed outside of the campsite's operational times. This approach allows the site to continue supporting elements of agricultural activity, such as grazing, thereby maintaining a level of agricultural functionality. Additionally, the balance achieved between temporary development and agricultural use aligns with Strategic Policy 8, enabling the site to contribute positively to both tourism and local land use practices.
• 7.3 ENVIRONMENTAL IMPACT (EP24)

• 7.3.1 Appendix 5 of the Strategic Plan 2016 identifies the types of applications requiring an Environmental Impact Assessment (EIA), including permanent campsites. Until a Planning Policy Statement (PPS) is prepared to specify how such applications will be handled, they are assessed against the UK Town and Country Planning (Environmental Impact Assessment) Regulations

1. Schedule 2 of these regulations mandates an EIA for campsites or caravan sites exceeding 1 hectare, with the application site, at 9.51 acres (approximately 3.85 hectares), meeting this threshold.

• 7.3.2 The application includes an environmental report that aims to fulfil the EIA requirements. However, it is important to note that these reports when put together would not pass for a comprehensive EIA. However, given the campsite's limited operational periods and overall size, and site context, on balance it is not considered a full EIA is required in this case. The submitted statement, while lacking some elements typically expected for larger permanent campsites, is acceptable due to the nature of the current scheme and the limited permanent structures. Exemptions are deemed reasonable when compared to large-scale developments referenced in Paragraph 9.5.3 of the Strategic Plan.

- 7.4 VISUAL IMPACT (EP1 & GP2)

• 7.4.1 The proposed campsite, covering approximately 9.51 acres, is located within an established agricultural landscape, bordered by hedgerows and grassland. The mature landscaping, hedgerows, and wooded areas provide natural screening, ensuring that the visual impact of the development will remain limited. Consequently, the designated camping areas will be largely obscured by these boundary treatments.
• 7.4.2 The layout of the site has been carefully planned to uphold the visual coherence of the area. The motorhome pitches are positioned along the northern boundary, maintaining a setback of approximately 13 meters from existing hedgerows to preserve the landscape's visual integrity. The tent pitches are situated at the centre of the site, ensuring that the surrounding hedgerows and key landscape features are left undisturbed. To further mitigate visual impacts, structural planting will be incorporated between tent rows and around the amenities area, contributing to a cohesive and visually appealing environment.
• 7.4.3 Although the proposal seeks approval for a permanent campsite, its operational use will be limited to less than six months annually. This temporary usage significantly reduces longterm visual impacts. During non-operational periods, the site will revert to agricultural use, supporting animal grazing and retaining its rural character.
• 7.4.4 The scale of the development has been thoughtfully balanced with its surroundings. The reception, the only permanent structure, will have a modest height of approximately 3 meters, ensuring it remains inconspicuous within the landscape. Other facilities, such as portacabinstyle buildings, are concentrated on existing hardstanding areas to further minimize visual intrusion. Temporary features, including a marquee for events during the TT and MGP periods, are confined to limited timeframes and do not contribute to permanent impacts.
• 7.4.5 Additional measures, such as solar-powered low-level lighting and informal planting, are designed to blend the campsite seamlessly into its surroundings. These planning and design choices effectively minimize adverse visual impacts, maintaining alignment with Environment Policy 1 and General Policy 2.

- 7.5 IMPACT ON NEIGHBOURS (EP 22, CP 7 & GP 2)

• 7.5.1 One of the key considerations for this proposal is its potential impact on neighbouring properties, particularly regarding noise. This is especially relevant due to the proximity of the closest residential neighbour, Boayl Chirrym, West Kimmeragh Road, which is located approximately 65 meters from the nearest tent pitch. Notwithstanding, the existing trees along the property boundaries would function as natural sound buffers, helping to diminish any potential noise disturbance. Furthermore, the marquee, identified as the primary noise source, is situated 235 meters from this property, significantly reducing the risk of disturbance. The campsite's operational period is limited to the TT and MGP racing festivals, ensuring that any noise impacts are confined to specific times of the year. These operational restrictions demonstrate an effort to minimize disruptions during non-festival periods and would serve to diminish disturbance of the area for neighbours.
• 7.5.2 In addition to mitigating noise, the proposal incorporates measures to address visual disturbance. Artificial lighting has been designed with minimal impact, using low-level lighting bollards positioned at hook-up points. Grass reinforcement along vehicular routes helps reduce dust and debris during the drier camping season. Additionally, these features enhance the usability of the site while respecting the needs of neighbouring properties. Mature hedgerows provide natural screening for motorhome lines, mitigating both visual and noise impacts and preserving the character of the site.
• 7.5.3 While the site will experience an increase in activity compared to its current use for agriculture, its location on a main route already accustomed to high volumes of passing traffic mitigates the effect of additional movements. This ensures that the potential impacts of increased comings and goings are not anticipated to result in undue impacts. Moreover, the existing traffic infrastructure supports the additional movements in a manner that aligns with maintaining local residential amenity.
• 7.5.4 When viewed as a whole, the proposal has been designed with a balanced approach, considering noise, visual impacts, and traffic concerns. Consequently, it is considered to comply with the requirements of Environment Policy 22 and Community Policy 7 of the Strategic Plan, demonstrating that the development will not result in unacceptable harm to amenity of neighbouring amenity.

- 7.6 PARKING AND HIGHWAY SAFETY (TP 4, 7 & GP2)

• 7.6.1 Parking for the proposed campsite will be confined to designated areas within the tent and motorhome pitches, with the allocated spaces adequately designed to accommodate the anticipated number of visitors. The 12 motorhome pitches will feature permeable hardstanding, while the 60 grass tent pitches will ensure sufficient capacity without encroaching on surrounding areas. Vehicular access to the site will be provided via a priority crossroads junction on the A17 West Kimmeragh Road. This access benefits from visibility splays of 2.4m x 215m, meeting the standards required for the posted speed limit. A secondary access point, reserved for staff and service vehicles, will connect directly to the RAF Andreas perimeter track.
• 7.6.2 Internal transport arrangements have been carefully designed to ensure safe and efficient circulation throughout the site. The internal roads will be widened to accommodate two-way vehicular movements, while 2m-wide permeable pedestrian pathways will provide safe access to communal facilities. These pathways will support connectivity within the site and enhance accessibility for all visitors.
• 7.6.3 To promote sustainable transport, the applicant has committed to issuing visitor information packs to all guests upon arrival. These packs will include details of public transport options, such as the ConnectVILLAGES on-demand service, local bus routes, and a dedicated shuttle service to and from Ramsey operated by the applicants. In addition, the packs will provide guidance on safe pedestrian routes, directing foot traffic via the former airfield road to Oatlands Road, thereby avoiding the A17.

• 7.6.4 DOI Highways have reviewed the proposals and confirmed that they raise no significant concerns regarding road safety or highway network efficiency. Subject to the implementation of the outlined measures, including internal road widening and safe pedestrian routing, the development is considered acceptable in highway terms.
• 7.6.5 While the provision of visitor information packs has been requested by DOI Highways as a measure to promote sustainable travel and enhance pedestrian safety, it should be noted that the provision and dissemination of such packs are operational matters that fall outside the scope of planning control. Consequently, while these measures are encouraged, they cannot be secured or enforced through planning conditions. As such, no additional planning conditions have been included to address this matter.
• 7.6.6 Accordingly, the proposal satisfies the requirements of Transport Policies 4 and 7, as well as General Policy 2, ensuring that parking and highway safety provisions are both practical and compliant with the Strategic Plan.
• 7.7 IMPACT ON ECOLOGY (EP 1 & 4, & GP 2)

• 7.7.1 The semi-improved grassland on the site, although currently of low ecological value, provides an opportunity for biodiversity enhancement. Measures such as re-seeding with species-rich hay and phased cutting schedules can transform it into a botanically diverse meadow, benefiting invertebrates, birds, and bats. Additionally, the field boundaries, comprising hedgerows and scattered shrubs, serve as important habitats and ecological corridors. The proposal includes measures to minimize disturbance and maintain ecological connectivity, aligning with Environment Policies 4 and 5.
• 7.7.2 The DEFA Biodiversity team has reviewed the application and confirmed that the ecological assessment, conducted by Curragh Environmental Consultancy (CEC) in December 2024, is comprehensive. They support proposed mitigation measures, including habitat restoration, a habitat management plan, and sensitive lighting to minimize impacts on nocturnal wildlife, in line with the Bat Conservation Trust and Institute of Lighting Professionals Guidance Note 8/23 (2023). DEFA has also suggested specific conditions to ensure compliance with Strategic Policy 4 of the Isle of Man Strategic Plan 2016, which emphasizes the protection and enhancement of landscape quality and biodiversity.
• 7.7.3 The proposed development incorporates these recommendations through measures such as replacement planting of grassland and scrub habitats, alongside the submission of a habitat management plan to guide the long-term ecological management of the site. These steps ensure compliance with Strategic Policy 4, offsetting ecological impacts while enhancing biodiversity.
• 7.7.4 Recommended conditions address soft landscaping, habitat management, and sensitive lighting, ensuring the replacement and maintenance of planting, the sustainable management of ecological features, and the minimization of impacts on wildlife.
• 7.7.5 Beyond mitigation, the proposal integrates additional ecological enhancements, including structural planting along field boundaries and sustainable practices, such as low-density winter grazing. These measures will improve habitat diversity while visually integrating the development into its surroundings.
• 7.7.6 The Curragh Environmental Consultancy's Ecological Assessment, alongside DEFA Biodiversity's recommendations, demonstrates that both anticipated and potential ecological impacts are being effectively addressed. The proposed measures comply with Environment Policies 4 and 5 and Strategic Policy 4, showcasing a commitment to safeguarding biodiversity and integrating sustainable ecological practices into the development.

- 7.8 LOSS OF HIGH-QUALITY AGRICULTURAL LAND (EP 14)

• 7.8.1 EP14 stipulates that development which would result in the permanent loss of important and versatile agricultural land (Classes 1-2) will not be permitted except where there is an overriding need for the development, and land of a lower quality is not available and other policies in this plan are complied with. The proposal site is shown to be on the boundary between Class 2 and 4/3 soils, with the camping areas where the permanent features are to be situated within class 4/3. Accordingly, it is considered that although the southern boundary of the site is within Class 2 soils which must be protected, the camping areas and the permanent features on site are within land area with Class 4/3 soils. Therefore, it is considered that the proposal would be acceptable in this regard.

- 7.9 OTHER MATTER

• 7.9.1 The following concerns, raised by the Owners/Occupiers of Boayl Chirrym, West Kimmeragh Road, are noted but fall outside the remit of the planning application. It is important to emphasize that it is not the role of the planner to amend an applicant's application. As such, matters that refer to conditions to amend the scheme cannot be controlled by planning conditions, as doing so would materially alter the scheme proposed:

• i. Site Size and Exclusion of Adjacent Areas: The request to exclude the triangular portion of land directly adjacent to the objectors' property. The configuration and extent of the site are determined by the applicant's design and as such cannot be altered by planning conditions.
• ii. Reduction in Number of Pitches: Proposals to reduce the number of pitches are matters that rest solely with the applicant and cannot be altered through planning conditions.
• iii. Clarity on Utilities and Sustainable Design: The provisions for sewage, electricity, water, and internet, are operational considerations outside the scope of planning control.
• iv. Pollution Monitoring: The request for periodic pollution monitoring pertains to public health and environmental health, and as such fall outside the remit of planning.

- 8.0 CONCLUSION

8.1 The proposal demonstrates that it fulfils the need for a campsite of this standard in this specific location, with no reasonable alternatives available and a clear national demand. The development integrates camping-related infrastructure in a way that respects the character of the site and its surrounding countryside.

8.2 The submission provides sufficient environmental information to evaluate the permanent use of the land, given the nature and scale of camping use proposed within the scheme. Evidence also confirms that the expected increase in traffic can be accommodated effectively, without compromising parking or highway safety. Moreover, the scheme incorporates measures to address the loss of agricultural land, ensuring justification for its use while confirming the absence of viable alternatives.

8.3 Additionally, the 65-meter distance between the nearest camping tent location and the neighbouring dwelling, along with the mature landscaping and trees enclosing the boundary, provides natural screening and mitigates potential impacts on residential amenity. It should be noted that, whilst operational matters fall outside the control of planning, the presence of established campsite management controls, such as curfews and responsive on-site oversight, serves to ensure that any erring behaviour by visitors is dealt with effectively, thereby reducing the potential for disturbances.

8.4 In conclusion, the proposal is assessed to meet the requirements of Strategic Policy 8, Transport Policy 4, Environment Policies 1 and 24, and General Policy 3 of the Strategic Plan. Furthermore, it supports the principles outlined in the Department for Enterprise IOM Destination Management Plan 2016-2020 and the Non-Serviced Accommodation Futures Study (March 2017). This assessment confirms the acceptability of the application.

- 9.0 RIGHT TO APPEAL AND RIGHT TO GIVE EVIDENCE

9.1 The Town and Country Planning (Development Procedure) Order 2019 sets out the process for determining planning applications (including appeals). It sets out a Right to Appeal (i.e. to submit an appeal against a planning decision) and a Right to Give Evidence at Appeals (i.e. to participate in an appeal if one is submitted).

9.2 Article A10 sets out that the right to appeal is available to:

• o applicant (in all cases).
• o a Local Authority; Government Department; Manx Utilities; and Manx National Heritage that submit a relevant objection; and
• o any other person who has made an objection that meets specified criteria.

9.3 Article 8(2)(a) requires that in determining an application, the Department must decide who has a right to appeal, in accordance with the criteria set out in article A10.

9.4 The Order automatically affords the Right to Give Evidence to the following (no determination is required):

• o any appellant or potential appellant (which includes the applicant);
• o the Department of Environment, Food and Agriculture, the Department of Infrastructure, and the local authority for the area;
• o any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and
• o in the case of a petition, a single representative.

9.5 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 the Right to Appeal.

I can confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to the it by the appropriate DEFA Delegation and that in making this decision the Committee has agreed the recommendation in relation to who should be afforded Interested Person Status.

Decision Made : Permitted Committee Meeting Date: 17.03.2025 Signed : P VISIGAH Presenting Officer Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report). Signatory to delete as appropriate YES/NO See below

Customer note This copy of the officer report reflects the content of the file copy and has been produced in this form for the benefit of our online services/customers and archive records.

PLANNING COMMITTEE DECISION 17.03.2025 Application No. : 24/90966/B Applicant : Silly Moos Campsite Limited Proposal : Change of use of land to create a camp site with associated access tracks, hard standings, motorhome and tent pitches, reception and temporary communal facilities Site Address : Field 124689 West Kimmeragh Road Bride Isle Of Man IM7 4BB Planning Officer : Paul Visigah Presenting Officer As above Addendum to the Officer’s Report

The Planning Committee considered the application at its meeting on 17 March 2025 and agreed with the recommendation to approve the application subject to the officer's amendment of conditions 2, 4 and 8.

Amended Conditions shall read:

C 2. This approval relates to the use of the area edged red and shown for camping pitches, and for a maximum of 12 motorhome pitches and 60 standard grass tent pitches within the site during the approved period of operation.

Reason: To ensure proper control of the development and to reflect the information provided in the application, as the Department has assessed the impact of the proposal on the basis of the specific use and the documents submitted. The development is within an area not zoned for development and permission has been granted as an exception.

C 4. The temporary structures hereby approved shall be erected no sooner than 10 days before the first designated practice, and shall be removed no later than 3 days after the final race, of any of the following events:

• o Isle of Man TT; and
• o Manx Grand Prix. The accommodation on the site hereby approved (including any motorhome or tent) shall be
• occupied no sooner than 3 days before the first designated practice, and shall be removed no later than 3 days after the final race, of any of the following events:
• o Isle of Man TT; and
• o Manx Grand Prix.

Reason: To ensure proper control of the development and to reflect the information provided in the application, as the Department has assessed the impact of the proposal on the basis of the specific use and the documents submitted.

C 8. The development hereby approved shall be carried out strictly in accordance with the submitted waste management plan and retained as such thereafter.

Reason: To ensure the development operates in an environmentally responsible manner and minimizes waste impact.