ADD Agents Supplementary Statement

6th December 2022

Ref: 1612/4.2.4

Planning and Building Control Directorate Department of Environment, Food and Agriculture First Floor, Murray House, Mount Havelock Douglas, Isle of Man, IM1 2SF

Dear Sir/Madam, Re: P.A. 22/00186/B

Marshals’ Viewing Platform and associated works at Glen Moar Cottage 3 & Field 312273, Glen Helen Road, Laurel Bank St Johns IM4 3NN

Further to our previous letter of 29th March, we are glad to have had contact from the case officer more recently assigned to our Client’s Application (under the above reference), which we understand is now being progressed towards a decision.

We note no further representations since our previous letter, save for the relevant authorities’ reconfirmations that the Proposal does not present unacceptable risk to protected species, nor highway safety.

Our previous letter noted the unfortunate description by which the Application was publicised, which summarily omitted reference to the marshals’ platform — being the principal element of the Proposal notwithstanding the descriptions provided in our submissions.

We consider the potential for any confusion arising from this omission to be apparent and would be grateful if this letter were considered as part of the Application bundle, if only for the avoidance of any doubt.

(cont.)

Tel: +44 (0)1624 835222 Email: [email protected] Registered in IOM: 104985C VAT number: 002 0577 30 Directors: D.F. Lewis, J. A. Lewis, W. J. Newton Registered Office: The Old Chapel, 32-34 Malew Street, Castletown, IM9 1AF

Regarding the principle of marshal platforms, the submitted Statement provides a schedule of previous applications for the same purpose. These were approved within the countryside (as defined in the same area plan that remains in effect on the Site), often in prominent and elevated locations visible from considerable distances, particularly on sections of the mountain road. It should be noted that views towards the Site within the surrounding valley (much of which does not constitute public realm) are oblique and far more restricted, particularly as the adjacent highway is retained above the level of the Site.

Our investigation of public records from the previous forty years has not revealed any such application having been refused, indicating that the balance of interacting policies has consistently fallen on the side of providing such course-side facilities as a necessity. Such necessity is clear; ensuring the safety of road racing events is an essential function and adequate facilities must be provided to marshals to discharge this duty. Facilities (such as the Proposal) are particularly important once the arterial routes serving isolated locations (such as the Site) are severed during race events.

In the case of the Site, the land in question falls within an area of modified topography, formed when the adjacent highway was developed. Land use is limited in such circumstances, precluding the possibility of activities such as agriculture. The Proposal nevertheless incorporates existing topographical features, including a dry stone wall.

The Statement also records the Site’s planning history. PA 21/00151/B concerned the express approval of the conversion of a former garage to provide additional accommodation to Cottage 3 (for which the provisions of the Permitted Development Order had been relied upon). This converted space communicates internally with Cottage 3 and, for the avoidance of doubt, does not constitute a separate dwelling nor stand-alone accommodation. The agent’s submissions included drawings and photographs of the development, showing a stepped access to the flat roof above. The applicant’s supporting letter of 8th February 2021 (which we enclose for ease of reference) adds useful context and disclosed to the Department how this development formed part of broader plans intended for the Site as a whole.

We consider “Our Island Our Future: Isle of Man Visitor Economy Strategy 2022-2023” (adopted by Tynwald Court on 17th May 2022) to align with our Client’s cited objective to provide accessible facilities. The adopted strategic policy of the Isle of Man Government to “Strengthen existing events to improve their impact, visitor experience and financial sustainability”, forms a material consideration in favour of the Application.

Furthermore, any proposal serving multiple uses lends additional justification for its implementation. The marshal box at Quarry Bends in Ballaugh, for example, is situated above conveniences at ground floor level. The majority of established marshal platforms were, however, approved without such additional justification. The proposed marshal platform has been devised to also provide conveniences to marshals and to improve accessibility to the existing spectator area.

(cont.)

In summary, we consider the Proposal to provide the same necessary function as has been previously approved at similarly isolated courseside locations, to provide additional functionality over those previous approvals, to be less visually intrusive than those previous approvals, and to align exactly with adopted government policy devised to support visitor growth and experience introduced since those previous approvals.

We trust the above is self-explanatory, but for any clarification as may be required, please do not hesitate to contact the undersigned at this office.

Yours Sincerely,

Redacted

Euan P. H. Craine B.Arch, M.Arch, ADPPA, ARB, RIBA

Encl: Applicants letter in support of PA /2100151B 8th February 2021