DEC Officer Report

Application No.: 20/00165/C Applicant: Castletown Metropolitan Football Club Proposal: Temporary use for the creation of a camp site / motorhomes from the week prior to the TT festival to the week after the Festival of Motorcycling on an annual basis Site Address: Castletown Metropolitan Football Club Stadium Malew Road Castletown Isle Of Man IM9 4EA Principal Planner: Miss S E Corlett Expected Decision Level: Planning Committee Recommended Decision: Permitted Date of Recommendation: 15.04.2020 _________________________________________________________________

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 14 of the Town and Country Planning (Development Procedure) (No2) Order 2013 and to avoid the accumulation of unimplemented planning approvals.

• C 2. The site may accommodate up to 100 tents and up to 20 motorhomes as shown in the submitted drawings and the period of use is restricted to the week before TT practice week to the week after the Manx Grand Prix/Festival of Motorcycling, including the time in between which also includes the Southern 100 races in any year. Reason: to accord with the submitted proposal.

This application has been recommended for approval for the following reason.

The application is for a temporary use of the site and is considered to support the Government's Visitor Strategy for the provision of sport and recreation on the Island and would not have any adverse environmental impact.

Plans/Drawings/Information; This decision relates to drawings 1741-C-01 and C-01 both received on 12th February, 2020. _______________________________________________________________

Interested Person Status – Additional Persons

Department for Enterprise should be afforded Interested Person Status as they submitted material comments on the application. _____________________________________________________________________________

Officer’s Report

THIS APPLICATION IS REFERRED TO THE PLANNING COMMITTEE AS THE DEVELOPMENT COULD BE CONSIDERED TO BE CONTRARY TO THE DEVELOPMENT PLAN

THE SITE

1.1 The site is the curtilage of Castletown Football Club which is situated on the western side of Malew Road which leads north out of Castletown, from the bypass to Malew Church. The site lies, just within a 30 mph speed limited area: at the northern boundary of the site the speed limit changes from 30 mph to 60 mph to the north. - 1.2 The site includes a stadium and clubhouse which are situated in the southern part of the site, backing onto a lane which serves one existing house, approved development which has yet to be implemented and a large electricity substation building. The site also accommodates two football pitches, vehicular access from Malew Road and a car parking area. THE PROPOSAL

2.1 Proposed is the temporary use of the northernmost pitch for camping of tents and a motorhome camping area alongside the road. Low level solar lighting is proposed along the western part of the pitch to enable people to get to and from the campsite and clubhouse in darkness. Vehicular access would be from the entrance onto Malew Road, north to the eastern end of the pitch where there would be parking alongside the motorhome parking area. The layout is shown on drawing 1741-C-01 (described as "support info.pdf" on the Government website's online services). - 2.2 The proposal would accommodate up to 100 tents and up to 20 motorhomes and the period of use would be from the week before TT practice week to the week after the Manx Grand Prix/Festival of Motorcycling, including the time in between which also includes the Southern 100 races. - 2.3 This application follows an earlier one (see Planning History) which approved this use up until 2019. The camp site has been operational until then. The applicant is clear that the revenue from the camp site goes towards the development of the club which has over 100 junior players. This latest application proposes the temporary use with no restriction on how long into the future the use may continue for the specified periods within the year.

PLANNING POLICY

3.1 Section 10(4) of the Town and Country Planning Act states: "In dealing with an application for planning approval… the Department shall have regard to -

• (a) The provisions of the development plan, so far as material to the application,
• (b) Any relevant statement of planning policy under section 3;
• (c) Such other considerations as may be specified for the purpose of this subsection in a development order or a development procedure order, so far as material to the application; and
• (d) All other material considerations."

3.2 In light of the above, it is considered that the key documents are:

• o the Area Plan for the South (2013);

• o The Isle of Man Strategic Plan (2016);
• o The Draft Planning Policy Statement on the Economy (2012);
• o The Destination Management Plan (2016); and
• o The Non-Serviced Accommodation Study (2017).

3.3 All the documents are available on the government website, other than the NonServiced Accommodation Study (2017) which is available upon request from DfE. Area Plan for the South - 3.4 The site is designated on the Area Plan for the South adopted in 2013 as Open Space for the particular purpose of a playing field. - 3.5 As such, there is a presumption against development which would result in there being more than 5% of the site covered with buildings and against uses which would be detrimental to the open character of the site. Recreational use of the site is accepted along with structures and facilities complimentary to that. Isle of Man Strategic Plan (adopted 2016) - 3.6 In light of the above, it is considered the policies from the Isle of Man Strategic Plan (adopted 2016) set out below are relevant in the determination of this application. - 3.7 The Strategic Plan takes its lead from the Government aims which include the pursuit of manageable and sustainable growth based on a diversified economy which is intended to raise the standard of living of the people of the Island and to provide the resources to sustain and develop public services. It also includes the protection and improvement of the quality of the environment such that it continues to be an asset for future generations. - 3.8 The Strategic Aim is: "To plan for the efficient and effective provision of services and infrastructure and to direct and control development and the use of land to meet the community's needs, having particular regard to the principles of sustainability whilst at the same time preserving, protecting, and improving the quality of the environment, having particular regard to our uniquely Manx natural, wildlife, cultural and built heritage." - 3.9 The Strategic Aim is noted but not considered directly further, as the relevant aspects are unpacked by the relevant detailed policies which are identified below. - 3.10 Strategic Policy 1 states: "Development should make the best use of resources by:

• (a) optimising the use of previously developed land, redundant buildings, unused and underused land and buildings, and re-using scarce indigenous building materials;
• (b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space(1) and amenity standards; and
• (c) being located so as to utilise existing and planned infrastructure, facilities and services."

3.11 Strategic Policy 2 states: "New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions (2) of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3." - 3.12 Strategic Policy 4 states: "Proposals for development must:

• (a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings (1), Conservation Areas (2), buildings and structures within National Heritage Areas and sites of archaeological interest;

• (b) protect or enhance the landscape quality and nature conservation value of urban as well as rural areas but especially in respect to development adjacent to Areas of Special Scientific Interest and other designations; and
• (c) not cause or lead to unacceptable environmental pollution or disturbance."

3.13 Strategic Policy 8 states: "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." - 3.14 Strategic Policy 10 states: "New development should be located and designed such as to promote a more integrated transport network with the aim to:

• (a) minimise journeys, especially by private car;
• (b) make best use of public transport;
• (c) not adversely affect highway safety for all users, and
• (d) encourage pedestrian movement"

3.15 The Strategic Plan sets out a Spatial Strategy which includes a hierarchy of named settlements. The application site is not within a named settlement and therefore Spatial Policy 5 is relevant, which states, "New development will be located within the defined settlements. Development will only be permitted in the countryside in accordance with General Policy 3". - 3.16 General Policy 2 relates to "Development which is in accordance with the land use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan" and indicates that such proposals will be supported subject to compliance with a detailed list of issues. Proposals outside of allocated areas are assessed against General Policy 2 (see below). However, because the majority of the detailed considerations set out in General Policy 3 could be seen as 'standard' planning considerations, it can be helpful to consider whether a proposal complies with the detail of General Policy 2, even where it is not on land zoned for development. On that basis the following extracts from General Policy 2 are considered potentially relevant:

"…(b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them; (c) does not affect adversely the character of the surrounding landscape or townscape;

• (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;
• (e) does not affect adversely public views of the sea;
• (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks;
• (g) does not affect adversely the amenity of local residents or the character of the locality;
• (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space;
• (i) does not have an unacceptable effect on road safety or traffic flows on the local highways;
• (j) can be provided with all necessary services; … (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding; …"

3.17 General Policy 3 states: "Development will not be permitted outside of those areas which are zoned for development on the appropriate Area Plan with the exception of:

• (g) development recognised to be of overriding national need in land use planning terms and for which there is no reasonable and acceptable alternative"

3.18 Environment Policy 1 states: "The countryside and its ecology will be protected for its own sake. For the purposes of this policy, the countryside comprises all land which is outside the settlements defined in Appendix 3 at A.3.6 or which is not designated for future development on an Area Plan. Development which would adversely affect the countryside will not be permitted unless there is an over-riding national need in land use planning terms which outweighs the requirement to protect these areas and for which there is no reasonable and acceptable alternative." - 3.19 Environment Policy 2 states: "The present system of landscape classification of Areas of High Landscape or Coastal Value and Scenic Significance (AHLV's) as shown on the 1982 Development Plan and subsequent Local and Area Plans will be used as a basis for development control until such time as it is superseded by a landscape classification which will introduce different categories of landscape and policies and guidance for control therein. Within these areas the protection of the character of the landscape will be the most important consideration unless it can be shown that:

• (a) the development would not harm the character and quality of the landscape; or
• (b) the location for the development is essential."

3.20 Environment Policy 3 states: "Development will not be permitted where it would result in the unacceptable loss of or damage to woodland areas, especially ancient, natural and seminatural woodlands, which have public amenity or conservation value". - 3.21 Environment Policy 4 states: "Development will not be permitted which would adversely affect:

• (a) species and habitats of international importance:

• (i) protected species of international importance or their habitats; or
• (ii) proposed or designated Ramsar and Emerald Sites or other internationally important sites.

• (b) species and habitats of national importance:

• (i) protected species of national importance or their habitats;
• (ii) proposed or designated National Nature Reserves, or Areas of Special Scientific Interest; or
• (iii) Marine Nature Reserves; or
• (iv) National Trust Land.

• (c) species and habitats of local importance such as Wildlife Sites, local nature reserves, priority habitats or species identified in any Manx Biodiversity Action Plan which do not already benefit from statutory protection, Areas of Special Protection and Bird Sanctuaries and landscape features of importance to wild flora and fauna by reason of their continuous nature or function as a corridor between habitats.

Some areas to which this policy applies are identified as Areas of Ecological Importance or Interest on extant Local or Area Plans, but others, whose importance was not evident at the time of the adoption of the relevant Local or Area Plan, are not, particularly where that plan has been in place for many years. In these circumstances, the Department will seek site specific advice from the Department of Agriculture, Fisheries and Forestry if development proposals are brought forward."

3.22 Environment Policy 5 states: "In exceptional circumstances where development is allowed which could adversely affect a site recognised under Environmental Policy 4, conditions will be imposed and/or Planning Agreements sought to:

• (a) minimise disturbance;
• (b) conserve and manage its ecological interest as far as possible; and
• (c) where damage is unavoidable, provide new or replacement habitats so that the loss to the total ecological resource is mitigated."

3.23 Environment Policy 7 states: "Development which would cause demonstrable harm to a watercourse, wetland, pond or dub, and which could not be overcome by mitigation measures will not be permitted. Where development is proposed which would affect a watercourse, planning applications must comply with the following criteria:

• (a) all watercourses in the vicinity of the site must be identified on plans accompanying a planning application and include an adequate risk assessment to demonstrate that works will not cause long term deterioration in water quality;
• (b) details of pollution and alleviation measures must be submitted;
• (c) all engineering works proposed must be phased in an appropriate manner in order to avoid a reduction in water quality in any adjacent watercourse; and
• (d) development will not normally be allowed within 8 metres of any watercourse in order to protect the aquatic and bankside habitats and species."

3.24 Environment Policy 13 states: "Development which would result in an unacceptable risk from flooding, either on or off-site, will not be permitted". - 3.25 Environment Policy 22 states: "Development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties in terms of:

• i) pollution of sea, surface water or groundwater;
• ii) emissions of airborne pollutants; and
• iii) vibration, odour, noise or light pollution."

3.26 Environment Policy 24 states: "Development which is likely to have a significant effect on the environment will be required:

• i) to be accompanied by an Environmental Impact Assessment in certain cases; and
• ii) to be accompanied by suitable supporting environmental information in all other cases."

3.27 Paragraph 7.18.1 states: "Environmental Impact Assessment (EIA) is an important procedure for ensuring that the likely effects of new development on the environment are fully understood and taken into account before the development is allowed to go ahead. It is a process by which information about the likely environmental effects of certain types of development is collected, assessed and taken into account by the developer (as part of project design) and by the planning authority (in determining the acceptability of the application). In cases where developments are likely to have significant environmental effects, whether public or private, by virtue of their nature, size or location, EIA's will be required and the general principles set out in Appendix 5 should be followed." - 3.28 Appendix 5 of the Strategic Plan states that an Environmental Impact Assessment (EIA) will be required in all cases where the proposed development comprises a "permanent camp site and caravan site". - 3.29 Business Policy 1 states: "The growth of employment opportunities throughout the Island will be encouraged provided that development proposals accord with the policies of this Plan." - 3.30 Paragraph 9.5.3 states: "It is considered that the Island's primary assets to tourists and visitors alike are its unique historical landscape, culture and heritage, as well as a wide range of specialist events and attractions. Many activities and facilities providing for the Island's tourists require no permanent development: the TT Races, for example which attract by far the most significant number of tourists to the Island of any event held here, require little but the Grandstand on Glencrutchery Road and a small number of modest marshals' shelters around the Course. Tourism can, however require the erection of built structures - holiday

• accommodation being the most frequently requested form of new development required in association with the tourism industry. It is important that a balance be struck between the needs of tourism and the protection of these assets, and that tourism development should be sustainable in accordance with the objectives of this plan. There is no special reason why less demanding policies should be applied to tourism development than for other types of development in the countryside, and larger scale schemes may have to be the subject of an environmental impact assessment before planning permission is granted, as with any other form of large scale development."
• 3.31 Business Policy 11 states: "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. Within the rural areas there may be situations where existing rural buildings could be used for tourist use and Environment Policy 16 sets out the circumstances where this may be permitted."
• 3.32 Business Policy 14 states: "Tourism development may be permitted in rural areas provided that it complies with the policies in the Plan. Farmhouse accommodation or quality self catering units in barn conversions and making use of rural activities will be encouraged but must comply with General Policy 3 and Business Policies 11 and 12. Other forms of quality accommodation in rural areas will be considered, including the provision of hostels and similar accommodation suitable for walkers but must comply with General Policy 3 and Business Policies 11 and 12."
• 3.33 Recreation Policy 3 states, "Where appropriate, new development should include the provision of landscaped amenity areas as an integral part of the design…".
• 3.34 Community Policy 10 states, "Proposals for the layout and development of land will be permitted only where there is provided proper access for fire-fighting vehicles and adequate supplies of water for fire-fighting purposes".
• 3.35 Community Policy 11 states, "The design and use of all new buildings and of extensions to existing buildings must, as far as is reasonable and practicable, pay due regard to best practice such as to prevent the outbreak and spread of fire".
• 3.36 Transport Policy 1 states, "New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes".
• 3.37 Transport Policy 4 states, "The new and existing highways which serve any new development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan."
• 3.38 Transport Policy 6 states: "In the design of new development and transport facilities the needs of pedestrians will be given similar weight to the needs of other road users."
• 3.39 Transport Policy 7 states: "The Department will require that in all new development, parking provision must be in accordance with the Department's current standards. The current standards are set out in Appendix 7."
• 3.40 Transport Policy 8 states: "The Department will require all applications for major development to be accompanied by a Transport Assessment."
• 3.41 Infrastructure Policy 5 states: "Development proposals should incorporate methods for water conservation and management measures to conserve the Island's water resources".

The draft Planning Policy Statement Planning & the Economy (2012)

3.42 The weight to be attached to that document would obviously be greater if the review promised in paragraph 26 of the "Initial Summary of Responses" had been carried out, and also if a final PPS had been laid before Tynwald and published in accordance with Section 3(3) of The Act. Further, it has been 8 years since the originally laid before Tynwald and little if anything has been undertaken since. Accordingly, it could be considered as time has gone by, its weight lessens. It is also considered that the weight to be attached to the draft PPS would be greater if paragraph 14 of that document recognised the primacy of the development plan (as required by Section 3(4) of the Act), rather than suggesting a less onerous test than is contained in General Policy 3(g) of the Strategic Plan. Nevertheless, the general thrust of draft PPS remains a material consideration, which reinforces Business Policy 1 of the Strategic Plan. - 3.43 With the above in mind, and also noting that the PPS is quite short and therefore in some ways the entire document has a relevance to the foregoing assessment, the extracts of the Draft PPS set out below are considered particularly relevant.

• o "The Government is committed to promoting a strong, stable, and productive economy that aims to bring jobs and prosperity for all. In doing so the Government is committed to delivering further economic growth and diversification."
• o "Achieving sustainable economic growth requires a fast, efficient and responsive planning system that includes a presumption in favour of development whilst protecting the countryside and enhancing the quality of the natural and built environment, which supports growth alongside regeneration, social and environmental sustainability, and has a greater emphasis on the quality of design."
• o "It is essential that the planning system considers, and makes appropriate provision for the identified national needs of the entire economy and assists in steering economic development to the most appropriate locations. The economy should not be constrained by a shortage of land for economic development uses."
• o "The planning system should support economic and employment growth alongside social and environmental sustainability. There is a general presumption in favour of development. Proposals will be considered on their merits bearing in mind the Development Plan and the need to protect the island's unique character, natural environment and quality of life."
• o "For planning purposes the Isle of Man Government defines economic development as the development of land and buildings for activities that generate wealth, jobs and incomes. Economic development land uses include: the traditional employment land uses (offices, research and development, industry and warehousing), as well as retail, leisure, and public services."
• o "Although for planning purposes, it is not defined as economic development, it is recognised that house building and construction do play a valuable role in the economy."
• o "In so doing, the planning system will aim to:
• o Recognise that economic development can often deliver environmental and social benefits;
• o (iv) Through the Development Plan ensure that suitable locations are available for industrial, commercial, retail, housing, public sector (e.g. health and education) tourism and leisure developments, so that the economy can prosper;
• o (v) Provide opportunities for land and premises to enable for improved productivity, choice and competition, particularly when technological and other requirements of modern business are changing rapidly;

• o (vi) Recognise that the economy will always be subject to change; therefore planning will need to be sensitive to these changes and the implications for development and growth;
• o (viii) Work with the Department of Economic Development and other Government Departments to identify opportunities for future investment to deliver economic objectives;
• o (ix) Ensure that economic and employment growth supports regeneration, social and environmental sustainability."
• o "In the national interest, it is important that Planning Officers, the Planning Committee and Planning Inspectors adopt a positive and constructive approach to determining planning applications for economic development, taking account of advice on the indicated economic benefits of the development alongside social and environmental issues."
• o "Planning will need to ensure that the economic benefits associated with a proposed project are understood and that these are given adequate material consideration with social and environmental issues in the decision making process. Therefore it is essential that any evidence is sufficient to meet these criteria. The decision makers in planning will continue to recognise that on occasions the economic benefits may outweigh social and environmental considerations."
• o "Well designed employment and residential uses can in some cases be compatible and planning should have regard to the proximity and compatibility of proposed residential development adjacent to existing industrial and commercial uses to ensure that both amenity and economic development opportunities are not unduly compromised."

Programme for Government

3.44 Programme for Government 2016 - 2021 (approved in Tynwald) states the Governments strategic objectives for the next five years and identifies the initial priorities. One of the three main objectives being "An Island of Enterprise and Opportunity" - 3.45 There are a number of objectives within this document which could be considered relevant to this application, as set out below.

• o "We have an economy where local entrepreneurship is supported and thriving and more new businesses are choosing to call the Isle of Man home"
• o "We have a diverse economy where people choose to work and invest"
• o "We are an Island where people choose to live and visit"
• o "We have a planning system which supports sustainable growth"

3.46 In terms of policies (under heading 'Sustainable Island') within this document, those set out below could be considered relevant.

• o "Make best use of our Island's land and seas for leisure and work through food, agriculture and fisheries strategies, plus tourism and recreational use that work together with
• our environment"
• o "Continue to promote and support our national heritage, culture and language at home and around the world"
• o "Build on and promote our UNESCO Biosphere accreditation for the benefit of our economy, environment and community"
• o "Grow the visitor economy in the Isle of Man"

• o "Make it easier for Government's priorities to be reflected in the way planning applications are considered"

Destination Management Plan 2016 - 2020 (Status accepted by Department of Enterprise (DfE) in 2016)

3.47 The Plan sets out five objectives, which include "Creating an exceptional visitor experience" and "Championing new investment and product development". The Plan indicates potential growth from UK families who are responsive to amongst other things, "self-catering, including camping at all price points". - 3.48 The Plan also identifies a number of key points in terms of the CURRENT situation:

• o that 2,800 people are directly employed in the Islands tourism sector (7% of available workforce);
• o There has been a 28% fall in bed spaces since 2003 (3% loss per year), these mainly being 1 & 2 star serviced accommodation (i.e. guesthouses being converted to residential units);
• o Self-catering sector has increased, especially the higher end (4 & 5 star);
• o Increase in 20 temporary campsites and rooms in residents homes during TT races;
• o There were 277,00 visitors to the IOM in 2014 (91% from British Isles) which had an
• overall spend of £107.7m;
• o In broad terms the volume of visits to the IOM over the last 12 years has seen a steadily fallen by an average of 1.7 a year (2014 were 16.5% lower than in 2003);
• o The current profile of visitors are; 47% of visitors are over 55+, stay for more than 4 days &68% of visitors are without children; and
• o Currently the forecast of the plan is there would be an continued growth in leisure visitors but a decline in business visitors and people visiting friends and relatives, resulting in an overall stagnation of visitor number sot the IOM up to 2020.

3.49 In terms of "Where we want to be" the plan identifies the following;

• o Shifting in focus to target potential growth in leisure markets, specifically the UK short break and family markets, and efforts to consolidate business and visiting friends and relatives markets which are currently in decline; and
• o A 2% increase per annum in tourism growth equates to 311,900 visitors and £122m value a 4% increase equates to 350,500 visitors and £137m value.

3.50 The Plan includes a chapter of "How we get there" in terms of the targets listed above, these are:

• o Effective Partnerships;
• o Promotion & Marketing;
• o Visitor Experience;
• o Product Development; and
• o Research & Intelligence.

3.51 Within the "Product Development", the plan identifies two "Primary Target New Growth Markets" these being:

"UK Families" - children ages 12 and under, short breaks 1 to 3 days, primary from North West, travel by car/ferry. These are responsive to beaches, self-catering including camping, holiday centres offering child focused facilities e.g. swimming pools, entertainment and general activity; safe and friendly.

"Short breaks" who on average stay 4 nights, aged 50+ couples; located in UK & near Europe, travel by car/ferry or budget airline, general holiday or special interest, higher spending than families and coach trips. These are responsive to range of type of accommodation, including

high end resort spa/golf resorts, quality places to eat in serviced hotels and resultants throughout the destination, special retail, arts and crafts & café culture, and broad range of cultural events, heritage attractions, natural environment and gentler activities such as walking.

3.52 The plan has also broken down the "Primary Growth Target Markets" into a specific set of detailed visitor profiles to gain a better understand their needs and better target our promotion and marketing. These fours are:

• o Out Timers-generally couples and groups of friends in their 60s;
• o Trusty Travellers - usually couples aged 50+;
• o Work hard, play hards - tend to be mid-20s to 40 something's; and
• o 2.4 explorers - adventurous families with children.

3.53 Key actions in relation to improving visitor services include, "Conduct an Accommodation Strategy to identify and direct current and future development of serviced and non-serviced accommodation" and "Work with Department of Infrastructure to review and assess the need for the development of a deep water berth for cruise ships and commercial marinas and "Work the Department of Environment, Food and Agriculture (DEFA) identify and assess suitable sites for the development of family orientated holiday centres". - 3.54 The IOM Destination Management Plan is an approved strategy of the Department of Enterprise, as such it is capable of being a material consideration.

Isle of Man Non-Serviced Accommodation Futures Study (March 2017) Status accepted by Department of Enterprise (DfE) in 2017

3.55 The Study was prepared by "Hotel Solutions" which is a hotel development consultancy, on behalf of the Department of Enterprise (formerly DED) following the recommendation so the IOM Destination Management Plan 2016-2020. The below four points outline the purpose, coverage & use of the Study:

• o "The Isle of Man Non-Serviced Accommodation Futures Study seeks to make an
• objective assessment of the future potential for non-serviced visitor accommodation development on the Isle of Man, both in terms of developing existing stock and new provision if evidenced by market need.
• o It covers self-catering holiday cottages, holiday apartments, holiday lodges and complexes, holiday resorts, campsites, touring caravan provision, glamping and youth and group accommodation - hostels, bunkhouses, camping barns and outdoor education centres.
• o The assessment has involved an audit of current non-serviced accommodation supply
• on the Island; a review of non-serviced accommodation provision and development trends in rural destinations in the UK and on comparator UK islands; a survey of the Island's existing non-serviced accommodation businesses to understand performance and market demand; interviews with holiday cottage and holiday lodge letting agencies; a review of non-serviced accommodation development proposals and potential development sites; stakeholder consultations; a review of relevant policy, strategy and research documents; and a survey of UK and international non-serviced accommodation operators and developers.

• The study will be used to shape a future development strategy for the sector, inform planning policy and decision-making on non-serviced accommodation proposals, guide DED interventions to support future development (including the FAS1), and ensure that Government and interested parties are aware of the prospects and potential of the non-serviced accommodation sector going forward."

3.56 The Study identifies that the IOM is lagging behind UK rural and island designations in terms of provision of most types of non-serviced visitor accommodation and it is missing out on

• business that could be attracted with a wider, better quality, more contemporary non-serviced accommodation product.
• 3.57 The overall conclusion for the need of Non-Serviced Accommodation of the Study states the following:

"The market research undertaken for the DMP showed that there are significant potential markets that can be attracted to the Isle of Man from the UK and Ireland in terms of the family holiday and break market, empty nesters and retired people coming for short breaks, and people that can be attracted for walking, outdoor activities, star gazing, and bird and wildlife watching. All of these markets are interested in staying in non-serviced accommodation.

Our assessment of the Island's current non-serviced accommodation offer and how it compares to UK rural destinations and other UK islands is that the Isle of Man does not currently have a sufficiently developed non-serviced accommodation offer to attract these markets and compete effectively for them. It has very little weather-proofed non-serviced accommodation, very little family-friendly accommodation, and very little activity-focused accommodation. While the Island has a good stock of generally high quality self-catering accommodation, compared to other destinations, the Isle of Man has:

• o A limited stock of luxury contemporary/boutique holiday cottages;
• o No holiday cottages with leisure facilities;
• o No holiday resorts;
• o No holiday lodge parks;
• o No holiday parks;
• o Very little high quality glamping, and nothing distinctive in terms of glamping
• o Only one 4 star campsite and no 5 star campsite;
• o A ban currently on towed caravans;
• o Limited provision in terms of hostels and bunkhouses.
• o From our review of planning approvals, discussions with the Island's existing non-serviced accommodation operators and land owners, and conversations with UK non-serviced accommodation operators and developers, it is evident that there is growing, and current live interest in bringing forward non-serviced visitor accommodation development schemes on the Isle of Man, including some of scale.
• o There are however three barriers to securing investment in non-serviced accommodation development on the Isle of Man. The cost of getting to the Island is an issue for some markets, particularly at off-peak times, when the market is more price-driven. The short tourist season
• on the Island and inclement winter weather pose significant challenges in terms of achievable occupancy levels on the Island, and the viability therefore of investment. Planning and policy restrictions also place a barrier on non-serviced accommodation development, particularly developments of any scale in the countryside, and the development of caravanning.
• o If the Destination Management Plan targets are to be achieved, and the Isle of Man is to realise its tourism potential, attract the identified target growth markets, extend its tourist season, and compete effectively as a holiday and short break destination, it is clear from our research that the Island needs:
• o More family-friendly non-serviced accommodation;
• o More weather-proofed non-serviced accommodation;
• o More activity-focused non-serviced accommodation;
• o The types of non-serviced accommodation that are successfully operating in UK rural destinations and on other UK islands.

• o High quality, distinctive accommodation that people will feel is worth the extra time and cost
• of travelling to the Isle of Man for is key.

• Some non-serviced accommodation developments of scale (holiday resorts, holiday lodge parks and holiday parks) need to be considered as part of the forward strategy."

3.58 The study finds there is the potential for a number of different types of Non-Serviced Accommodation on the IOM these being; Holiday Cottages / Holiday Apartments, Holiday Lodges, Forest Holiday Centres, Holiday Resorts, Holiday Lodge Parks and Holiday Parks, Golf Lodges, Fishing Lodges, Glamping, Campsites, Eco Camping, Camping pods, A Camping Shelter Network, Touring Caravanning, Seasonal Tourers, Motorhome Stopovers, Campervan/Motorhome Hire, Hostel and Bunkhouses, Accommodation at Attractions & Walker, Cyclist and Motorcyclist Friendly Accommodation. - 3.59 In terms of this application, the following type of accommodation as listed above have been included in full, being likely to be most relevant when determining the current application.

"Camping Pods A few of the Island's campsites have added camping pods to provide an alternative accommodation offer and help extend the season. They are generally attracting good demand, primarily from on-islanders. This suggests potential for campsites to add a few more camping pods.

There might be scope for camping pod resorts/encampments (15-20 units) with central communal socialising and cooking areas and outdoor activities. Such resorts would have appeal for the family market, family and friend group holidays and breaks, and activity groups e.g. walking, cycling and motorbiking groups."

"Walker, Cyclists and Motorcyclist Friendly Accommodation 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."

3.60 The concluding comments of the Study state; "o This is a time of great opportunity for the Isle of Man to grow its visitor economy. An increase in the supply of non-serviced accommodation is critical to achieving this. The Hotel Futures Study was primarily about renewing the Island's hotel offer, rather than increasing hotel capacity. This study has shown that the opportunities for increasing the Island's accommodation capacity, and growing staying visitor numbers, are much more about developing non-serviced accommodation.

• o The analysis has shown that the Isle of Man has already fallen considerably behind other Island and rural UK destinations in terms of the supply of high quality, distinctive, contemporary non-serviced accommodation that will attract the Island's target markets. Without intervention to accelerate investment in this sector that gap will widen, leaving the Isle
• of Man in an increasingly uncompetitive position as a destination, and undermining the potential for the visitor economy to play its part in the Island's future growth strategy.
• o The Isle of Man is in a strong position: the market opportunity is there, and there is developer, operator and investor interest in taking opportunities forward - including schemes that have the ability to be game-changers, and to really make a difference to the Island's visitor economy and profile as a holiday and short break destination. The opportunities can
• only be realised however, if non-serviced accommodation development sites and viable schemes can be delivered, which a more flexible planning approach and Government financial assistance have a key role to play in achieving. The Government can, and we believe should,

pick this up and run with it, leading the way with a positive, dynamic and enabling programme of pro-activity and support, and a 'can do' attitude that will ensure the non-serviced accommodation sector is given the freedom to flourish on the Island."

3.61 The Study is a piece of evidence base rather than a strategy in its own right, but highlights areas of potential action/focus which could help to deliver the Destination Management Plan and has been accepted by DfE on that basis. - 3.62 Furthermore, it is perhaps worth to note that permission shouldn't be granted on the first, second, third etc schemes which are submitted, as the "wrong site" could then have future implications on the viability of more suitable sites that may come forward in the future. Accordingly, it is vital any such application is carefully considered.

Policy on the development of Non-Serviced Accommodation (March 2019) Status accepted by Department of Enterprise (DfE) in 2019

3.63 Following the Non-Serviced Accommodation Study in 2017 the Department of Enterprise (DFE) have now produced a policy/strategy. This report states:

"There is current and growing interest in the development of additional non-serviced accommodation units, as such it is now viewed that the Agency (Visit IOM Agency), and the Department, should clearly articulate their policy in respect of such development."

3.64 The documents summarises the non-serviced accommodation on the Island which makes up 54% of the overall bed space, with the majority being single units across the IOM. It highlights that there are gaps of:

• 1. Complexes, particularly with leisure facilities;
• 2. Units adapted for those with disabilities;
• 3. Large units catering for groups; and
• 4. Luxury, boutique style properties.

3.65 It comments that there are 11 permanent camp sites and 21 temporary campsites (Motor cycling events only), with the majority being 3 star quality. There are a small supply of glamping operations, primarily add-ons to campsites, where two operate of a high standard, operating all year round and the remainder are seasonal and basic. It also comments there are no holiday cottages and leisure facilities; holiday resorts; or holiday parks/holiday lodge parks. Again the report comments that the ION is lagging behind the UK in terms of non-serviced accommodation and could be missing out on visitors who could be attracted with a wider range and better quality of non-serviced accommodation offering. - 3.66 The document also comments that in 2016, 292,328 visitors came to the IOM, spending £106m on accommodation, food and drink, shopping, entertainment and transport, equating to an average spend of £363 spend per person. 679 people were employed in the visitor sector, with a further 2129 in catering and entertainment. In total this represents approx 7% of all jobs in the IOM. - 3.67 The Vistor Strategy 2019-2023 seeks to; Promote and develop the IOM as a quality visitor destination; increase the employment rate in the visitor economy by 15% by 2023; and provide a first class visitor experience and enhancing perceptions of the IOM as a great place to visit, live, work and invest. To achieve these aims it is necessary for the Visit IOM Agency to develop polices which ensure the evolving demands of the Visitor Market continues to be met. It comments that the IOM does not have sufficient quality accommodation to meet our ambitions. - 3.68 In terms of the Policy, the documents indicates that:

"This policy is designed to provide a balance approach, supporting growth of the potential market, in terms of scale and quality, whilst not substituting or displacing current provision. As such, focus will be on the types of non-serviced accommodation identified as being in shortage within the study, namely:

• 1. Developments of multiple units;
• 2. Those that cater for families;
• 3. Those they cater for individuals with disabilities;
• 4. Proposals which incorporate leisure and entertainment facilities;
• 5. High quality, luxury, boutique developments;
• 6. Clusters or separate small scale units which complement existing tourist activities or leisure facilities;
• 7. Glamping units; and
• 8. Those catering for group experiences.

3.69 The high level policy positions is; "Visit IOM and the Department for Enterprise will actively support the development of non-serviced accommodation which meets agreed high level criteria and serves to complement and enhance the overall proposition for the visitor economy.". The document comments that this Policy does not lead to substitution or dilution of the existing visitor economy, such support will initially be limited to proposals which, in aggregate provide for the development of units equating to no more than 5% of the total nonserviced bed spaces as recorded during March 2019. A Strategic Approach is also listed which considered the short, medium and long terms. The end of the document indicates that the policy will be supported where it meets a number of high level components. These are listed (and considered) within the representations from the Department of Enterprise within paragraph 5.4.1 of this report. UNESCO Biosphere Isle of Man - 3.70 UNESCO Biosphere Isle of Man is all about keeping the Isle of Man a special place to live, work and visit. The Isle of Man is the first entire Island Nation in the world to receive this designation. - 3.71 The UNESCO Biosphere Isle of Man project does not seek to prevent any specific actions, but to promote enjoying and celebrating the Isle of Man to the full, making it an even better place to be and promoting engagement. - 3.72 The scope of the UNESCO Biosphere Isle of Man Pledge is deliberately broad and inclusive but the context of the Pledge principles are set out below.

• o "Protecting our natural resources - this could relate to anything you're trying to do better that will impact positively on our natural resources, from managing water use to planting trees.
• o Developing our economy in a sustainable way - doing business responsibly, balancing the need for growth with respect for our natural, social and cultural environment. Responsible businesses tend to be more resilient, contributing to a diverse economy which is more sustainable than a 'monoculture' economy.
• o Supporting and promoting our cultural heritage - for example, staff involvement in, or corporate sponsorship of, cultural events and groups.
• o Making our environmental impact positive wherever possible - closely related to the first principle of protecting our natural resources, this could include anything from energy saving and waste management measures to support of local environmental projects.
• o Engaging with the local community - through environmental, social or community groups, whichever fit best with your business. You'll find a wide range of groups listed under 'Who is involved?' on the Environmental/Cultural, Community and Educational pages.

• o Promoting our outstanding living landscapes through active involvement with Biosphere Isle of Man - being an ambassador for the project and advertising the fact that you support it, thereby encouraging others to get involved."

3.73 The Biosphere Reserves are about achieving a good working balance between people and nature' and the Accreditation reflects how the Isle of Man manages its environment, community and economy, acknowledging that all three components are necessary to achieve a sustainable situation. - 3.74 The Biosphere related guidance, as summarised below, is not formal planning policy but the designation is capable of being a material consideration.

PLANNING HISTORY

4.1 The site has been the subject of a number of applications to improve the facilities for the football club and the rifle range which also operates here. None of these applications is considered relevant to the consideration of the current application. More recently planning approval was granted through 16/00617/C for the use of the site on a temporary basis for camping - tents and motorhomes - during TT to the week after FoM and was approved on a three year basis until 2019. REPRESENTATIONS - 5.1 Department of Infrastructure Highway Services have no objection (28.02.20).

5.2 Castletown Commissioners have not commented at the time of writing.

5.3 Department for Enterprise confirm that the campsite is registered with them and is considered to be already contributing to the Department's Visitor Strategy and will continue to do so. They are content with the application (03.04.20). ASSESSMENT - 6.1 The temporary use of playing fields is becoming commonplace on the Island with many football and rugby clubs using their facilities in this way when they are not required for practice or matches in order to supplement their income. Indeed, pitches in Colby, Peel Road in Douglas, Ballafletcher in Braddan, Ballaoates Road in Braddan and Port Erin all accommodate temporary camp sites for the TT, Southern 100 or MGP periods, or a combination of these. The National Sports Centre and Ballakermeen Secondary School also accommodate this, all with planning approval.

6.2 The issues which can arise with such proposals are the visual impact of tents and motorhomes on the landscape, the impact of noise on those in neighbouring properties and the suitability of the access to accommodate additional use.

6.3 In this case, the visual impact of the proposal will be limited to the view by those using Malew Road and whose view is already characterised by goalposts, fencing and floodlights, all of which are visible over the relatively low roadside stone road: the view is otherwise very open towards the profile of the hills to the west. The appearance of tents and motorhomes will change this, the motorhomes particularly but it is not considered that this is significant, bearing in mind that the site is used and occupied by people training and playing football, and those spectating, at times. It is also relevant that the camping facilities will also increase the range of facilities available to those wishing the visit the Island, particularly associated with local events such as the Southern 100 and post and pre-TT and MGP races which are based in Castletown. Finally, it is also worth considering that the sports clubs around the Island offer opportunities for recreation which are in line with Government's various strategies on improving the quality and health of the Island and its people, also acknowledged in the Strategic Plan (Chapter 10). The funding of such clubs can be difficult and the provision of camping facilities can significantly boost clubs' funds which are then reinvested in the facilities available.

6.3 Access to the site is already in place and used by those visiting the matches held at the site players and spectators. The access is on the inside of a bend and as such has good visibility in both directions. The proposed use will generate additional use and the access will be used for longer periods of the year as a result of the camping but this is not considered to have any detrimental impact on highway safety. - 6.4 Another concern which has arisen following the increase in the provision of temporary camp sites is a potential over-provision which could have an adverse impact on the viability of permanent camp sites. Whilst competition is not usually a material consideration, in this case the permanent camp sites are either on land designated for such purposes (such as Laxey on Quarry Road or Peel on Derby Road) or have specific permission which was based upon the provision of permanent facilities such as showers and toilets. These facilities have generally been created with a view to their permanence and which have appropriate access, well designed buildings and landscaping, things that temporary camp sites often do not have. - 6.5 The temporary camp sites which have recently arisen fall into two general types: those which are associated with a sports club or organisation and others which are either associated with a private enterprise or indeed no existing operation. The first type have the benefit of bringing income to clubs and organisations which deliver sport and/or recreation to the Island's residents which is supported by the Strategic Plan and Department for Education, Sport and Culture's Strategy for Sport. - 6.6 In this case, the camp site has been operating previously and is registered with DfE. It is organised by a local sports club and is located relatively close to Castletown, supporting its shops and services and relatively sustainable in that respect. It is also right alongside the Southern 100 circuit which makes it ideal for the racing thereon - the Pre and Post TT and the Southern 100. Importantly, the application has the support of the DfE.

CONCLUSION

7.1 Whilst the provision of a campsite on this site is contrary to the land use designation as Open Space for a Particular Purpose (Playing Field), it is considered acceptable for the reasons stated above and subject to conditions limiting the period of usage mirroring those attached to the previous application referred to in 4.1 above.

INTERESTED PERSON STATUS

8.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:

• (a) the applicant (including an agent acting on their behalf);
• (b) any Government Department that has made written representations that the Department considers material;
• (c) the Highways Division of the Department of Infrastructure;
• (d) Manx National Heritage where it has made written representations that the Department considers material;
• (e) Manx Utilities where it has made written representations that the Department considers material;
• (f) the local authority in whose district the land the subject of the application is situated; and
• (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material. 8.2 The decision maker must determine:

• o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and
• o whether there are other persons to those listed in Article 6(4) who should be given Interested Person Status.

I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to it under the appropriate delegated authority.

Decision Made : …Permitted……….... Committee Meeting Date:…05.05.2020

Signed :………S BUTLER……………….. Presenting Officer

Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officerreport).

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 onlineservices/customers and archive records.