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19/00475/C Page 1 of 8
PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 19/00475/C Applicant : David Salkeld Proposal : Temporary use of adjoining field as a camp site with associated toilets and parking for the duration of the week before the TT festival until a week after the IOM Festival of Motorcycling Site Address : Perk Cottage Knock Froy Road Santon Isle Of Man IM4 1JD
Principal Planner: Miss S E Corlett Photo Taken : 21.05.2019 Site Visit : 21.05.2019 Expected Decision Level : Planning Committee
Recommendation
Recommended Decision:
Refused Date of Recommendation: 31.05.2019 __
Reasons for Refusal
R : Reasons for Refusal O : Notes attached to reasons
R 1. The site is not designated for development on the Isle of Man Planning Scheme (Development Plan) Order 1982: rather, it is identified as being within an area of High Landscape Value and Scenic Significance. The proposed camp site - its tents, motorhomes, parked vehicles and mobile shower and toilet units will be visible and would have a harmful impact on the countryside, contrary to Environment Policies 1 and 2 and General Policy 3 and General Policy 2b and g. It is not considered that there is sufficient justification for setting aside this objection, given the number of existing approved campsites and the absence of evidence that there is a need for any more.
R 2. There would be inadequate visibility of and from vehicles emerging from the site onto the A5 which would result in an adverse impact on highway safety, contrary to Transport Policy 4 and General Policy 2h and i. In addition, there is no safe footway access to the pedestrian crossing point to the east of the access which would provide safe pedestrian access to the existing footways on the other side of the road, contrary to GP2h and Transport Policy 6.
R 3. The application form is silent on the matter of the presence of trees on the site and the intensification of the use of the gated access by vehicles is likely to have an adverse impact on the trees closest to this entrance, either by the introduction of hard surfacing or through the compaction of the roots by vehicles manoeuvring through and past the trees. The loss of these trees would be contrary to General Policy 2f.
R 4. This site is not considered suitable for camping in that there are no areas of hard standing on which to park motorhomes and there are no facilities for wet weather accommodation, clothes drying or dry storage.
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19/00475/C Page 2 of 8
Interested Person Status - Additional Persons
None __
Officer’s Report
THIS APPLICATION IS REFERRED TO THE PLANNING COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT
THE SITE 1.1 The site is the residential curtilage of an existing house and garage, together with the field immediately to the north and west. The dwelling is accessed from Knock Froy Road which leaves the A5 Castletown Road to head south east, serving the application property, a number of other dwellings and the Knock Froy motocross track and associated clubhouse and car park, to end over 700m from the A5, at Knock Froy Farm. The field is served by a separate gate near the junction of the lane and the A5.
1.2 The road serves the application property, Perk Cottage together with Green Hedges, a bungalow on the opposite side of the road, beside which there is a lane leading to two larger dwellings, High Hedges and Cronk Froy. Knock Froy Road continues past the motocross course, Milandra and Knock Froy Bungalow before reaching Knock Froy Farm. Knock Froy Road is a public highway (minor road).
1.3 Perk Cottage has planning approval for replacement with a larger, two storey property. Planning approval also exists for the replacement of the garage with a larger building incorporating upper floor accommodation which must be used as such ancillary to the main dwelling, Perk Cottage (see Planning History). To date, the garage replacement has been implemented but works have not yet commenced on the replacement dwelling. It is understood that an application for approval under the Building Regulations has not yet been made for the replacement dwelling.
1.4 The field alongside the dwelling has its own access close to the A5. The field is 3 hectares in area and has been subdivided for the purposes of the application, into two parts, one (that closer to the A5) being 1.7 hectares.
1.5 The field has a boundary with Knock Froy Road which features a line of self seeded hawthorn, sycamore and ash trees which largely screen the field from view therefrom: from the A5 the field is partly screened by a grassed hedge in which there are, intermittently, trees and shrubs. There is a clear view into the site from the Ballacutchel Road opposite, which serves Mount Murray golf course, clubhouse, hotel and residential estate. Overhead services cross the road to the west of the cottage and terminate just short of the access into the site as well as through the roadside hedging in places.
1.6 The access is a field gate which sits between two posts. Beyond that, just within the field are two trees around which the access, which is not surfaced, leads into the field. The application form is silent on whether there are any trees within the site and specifically within 15m of the proposed development (Q17).
1.7 The A5 has no footways on this side of the road in the Douglas direction and the nearest crossing point is alongside the site, some 130m from the site entrance. In the other direction, the nearest crossing point is slightly closer and there is a grassed footway to this. There is a bus stop on the same side of the road as the application site, just to the north of the site entrance and one on the other side of the A5 with no crossing point directly in between the site and the bus shelter.
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19/00475/C Page 3 of 8
THE PROPOSAL 2.1 Proposed is the use of part of the site for camping for a period starting "one week before the TT festival" and extending until "one week after the Festival of Motorcycling (previously known as MGP week".
2.2 The site would accommodate up to 100 tents, glamping pods and up to 20 motor homes with provision for parking and toilet facilities. The location plan submitted shows the siting for the toilet and shower block (for which there is no information other than the site plan) which will be to the north of Perk Cottage, the site for the motorhomes which would be to the west of the toilet and shower blocks, alongside the Knock Froy Road boundary and screened therefrom by the existing hedging and trees. The tents would be arranged parallel with the A5 with parking in the middle of that half of the site. The other half of the site would be occupied by glamping pods, of which there is no information.
2.3 The supporting information explains that this proposal was submitted to the Department in July 2018 but at that time the planning fee would have been significant. As such, they waited until the fees were revised and then reapplied. They advise that they previously consulted Highway Services who found the proposal acceptable, using the field gate and the existing Knock Froy Road access from where visibility is "very good and sufficient" in both directions. Photographs are provided but no visibility splays shown on the drawings.
2.4 They refer to the Comis Hotel, Golf Club restaurant, Knock Froy Scramble Course, The Forge Restaurant and Ballavartyn Equestrian Centre and restaurant nearby which all provide catering facilities. They also refer to bus stops and crossing points in close proximity and they also refer to previous discussions with Knock Froy Scramble Centre to provide additional catering, bar and toilet facilities in the event of wet weather in addition to those provided on the application site.
2.5 They refer to the existing roadside screening which will help ameliorate the visual impact of the tents but they also refer to the "significant visual intrusions" of The Forge, Ballavartyn and Mount Murray with advertising and lighting which "will deflect any visual impact" of the proposed campsite.
2.6 The applicant explains that they have been in discussion with various suppliers of mobile shower and toilet facilities for the site as well as with Environmental Health in respect of these facilities.
2.7 They explain that the campsite would be under the direct control of the applicant who lives at Perk Cottage although discussions have been held with Redsky Tents Co who operate the campsite at Castletown Metropolitan Football Club who has provided advice. They consider that the campsite will have a limited additional impact on neighbours who already experience the use of the scramble track and the equestrian centre who have recently proposed a camp site with portable facilities - see Planning History) and none of the neighbours has raised any objection. They conclude by suggesting that there is an acknowledged and proven need for campsite facilities and this proposal is ideally located to service the TT, Southern 100 and MGP race goers within easy commutable distance of Douglas and the air and sea terminals with what they consider to be limited environmental impact on the neighbourhood and that consideration should not be prejudiced by the recent application for the campsite at Ballavartyn.
PLANNING POLICY 3.1 The site lies within an area designated on the Isle of Man Planning Scheme (Development Plan) Order 1982 as not for a particular purpose but of high landscape value and scenic significance. As such, there is a presumption against development as set out in General Policy 3 and Environment Policies 1 and 2. There are no policies which provide guidance on the
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provision of camp sites although Business Policy 11 sets out the general support for tourism developments which are in accordance with the other policies in the Plan.
3.2 Permanent camp sites would require the submission of an EIA under Environment Policy 24 and Appendix 5 of the Strategic Plan but as this is for a temporary period only, this is not required in this case although it should be noted that the period in which the camp site is proposed would extend to up to 16 weeks of the year.
3.3 Whilst the site is not designated for development, General Policy 2 sets out general principles of development which should be applied to all forms of development, whether or not the site is designated for that purpose. The relevant parts of GP2 that development should achieve are as follows:
(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; (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 and (i) does not have an unacceptable effect on road safety or traffic flows on the local highways".
PLANNING HISTORY 4.1 The redevelopment of Perk Cottage was approved under 17/00871/B and 17/00214/B.
4.2 Planning approval was very recently granted for the creation of a temporary camp site at Ballavartyn Equestrian Centre alongside under 19/00255/C. Whilst the application was submitted for the camp site to be used on a permanent basis between the period beginning with TT fortnight and ending after the Festival of Motorcycling, the approval granted was for this year's race periods only and without the camp site being operational between each of the race periods specified (TT, Southern 100 and Festival of Motorcycling). The conditions attached were as follows:
C 1. This approval relates to the use of the area edged red and shown for camping pitches, for the purposes of a maximum of 34 tents.
Reason: to reflect the details of the proposal.
C 2. The pitching of the camp site may occur no sooner than one week before each first practice of TT 2019, Southern 100 2019 and Festival of Motorcycling 2019 and must be removed no later than a week after the last race of TT 2019, Southern 100 2019 and Festival of Motorcycling 2019 with no use of the site for camping in between these three race events.
Reason: The camp site is proposed as a seasonal feature and the site is not designated for development. In addition, the Department is concerned at the number of seasonal camp sites around the Island, both in terms of the need for any additional sites and the impact of them on the various permanent camp sites there already are. The Department understands that the Department for Enterprise is undertaking a review of the campsites on the Island and that is would be inappropriate to approve additional seasonal campsites in advance of this review.
C 3. The camp site may not be set up until the stop sign at the entrance to the site has been relocated in accordance with condition 2 of 17/00059/D or the existing sign which was approved under this application, has been relocated further back so as not to obscure the visibility of drivers leaving the site.
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Reason: In the interests of highway safety.
C 4. The mobile toilet and shower facilities may be erected no sooner than one week before the first practice of TT 2019 and must be removed no later than one week following the last race of the Festival of Motorcycling, 2019.
Reason: to ensure that no structures remain on site once the camp site is no longer operational.
REPRESENTATIONS 5.1 Santon Parish Commissioners object to the application on the basis that the access is unsafe, advising that only recently the Commissioners, Minister for DoI and "MHK MR. Simmons" met at this location to assess the perceived dangers to school children and others boarding and alighting from public transport on such a busy road with fast traffic and limited, in places very poor, visibility. They also express concern about the increased number of applications for campsites and whilst they serve a purpose to accommodate the influx of visitors at certain times, they threaten to "litter our HLVSS countryside with camps which, unless very carefully controlled, may not be an asset to the Island in the long term". They describe the site as presently being occupied by containers and abandoned vehicles and would be all the better for having these removed, but if they were to be replaced by motorhomes and glamping pods, this would not necessarily be an improvement. Temporary tents in race periods may be acceptable, subject to public health requirements being met. They are concerned about the potential permanence of motorhomes and glamping pods or possibly varying type and quality and express a fear that the glamping pods could eventually achieve planning approval for all year round occupation which could devolve into low-quality, cheap housing within which a new stratum of Manx society will develop. The suggest that historically caravan sites have been discouraged and wonder how what is proposed sits with that. Finally, whilst the applicant makes reference to the Ballavartyn camp site, they had qualified support for this subject to assurance that the specified periods will not be exceeded (15.04.19) and on the basis that the site already has a properly established infrastructure and would lend itself to this purpose. Should planning approval be granted, they Commissioners would wish to see a condition which prevents the motorhomes being retained on the site outside the camp site periods (08.05.19).
5.2 DEFA Arboricultural Officer expresses concern at the impact of the proposal on three trees close to the gated entrance to the site if the access were to be formalised, through excavation and/or compaction and whilst it would be possible to introduce a cellular protection system, this is likely to be prohibitively expensive and it may be better to consider mitigation planting and the possible removal of the trees. He provides advice on where this could occur (21.05.19).
5.3 Highway Services object to the application on the basis that the existing gated access is unacceptably close to the junction of the minor and major roads and would not allow for the safe turning movements between the site and the A5. Visibility splays have not been shown but it is unlikely, given the restricted area available for manoeuvring that sufficient visibility is available in either direction: splays of 2.4m by 120m in each direction are required. They also note that the field is unsuitable for motorhomes and vehicles, although it would be suitable for motorcycles and whilst the applicant may have had discussions with other land owners, this is not included within the site so cannot be considered. The proposal, they consider would intensify the use of an unsafe access and could lead to an increase in traffic accidents on a high speed main road (10.05.19).
ASSESSMENT 6.1 In planning terms tourist development is treated the same as any other form of development in the countryside - that is, there is a presumption against it. However, it has been recognised that camping is becoming an important part of the Island's tourist attractions and an increasing popular form of tourist accommodation and understood that Department of
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Economic Development is generally supportive of initiatives which attract and accommodate more visitors to and on the Island, which is reflected somewhat in Business Policy 11. A number of camp sites have been approved - some brand new ("Silly Moos" in Lezayre, Ballaugh Glen, Knockaloe Beg, Glendown Farm in Port St. Mary, Ballamoar Farm, Ballaugh, Pennybridge in Kirk Michael, Ballakaighen in Onchan), others which have existed in an unauthorised form for some time and some of which now have approval (Glenlough in Marown, for example). Encouragement is given for such facilities to be grouped near to existing buildings and where possible, to complement existing operations on the same site, for example, Ballavartyn where there is a cafe, car parking and existing tourist accommodation.
6.2 There are no Strategic Plan policies which guide tourist related developments other than those which encourage the use of existing buildings (EP16). However, it is generally accepted that where there is a need for camping facilities in association with particular events on the Island, temporary camp sites can be acceptable, and this has been particularly successful on sports pitches: Douglas Rugby Club, Ballafletcher rugby, football and cricket grounds, Union Mills FC, Castletown Metropolitan FC, Foxdale AFC, Peel AFC, Rushen FC and Laxey AFC all operate temporary pitches and at times when the pitches are not used. The income from the use as a temporary camp site can provide much needed support for social and sports organisations. Most recently permission was granted for the temporary use of Cronkbourne Cricket Club for this purpose on a temporary basis (18/01163/C) and Ronaldsway Social Club (19/00065/C). Most recently planning approval was granted to Foxdale Heritage for the use of Foxdale Football Club grounds for a camp site during TT and Festival of Motorcycling fortnights for 2019 and 2020 only (19/00322/C).
6.3 In this case, there are no existing facilities on site and whilst reference is made to Knock Froy Scramble Centre, this is not within the defined site and there is nothing from them which assures us that catering facilities or access would be available at any time to those on the camp site. Reference is made to other nearby catering facilities: Ballavartyn cafe appears from their website to be only open on event days and at the weekend: Mount Murray Golf Club is open from 0700 - 2100 hrs each day; The Forge operates from 1200 to 2130hrs and Comis Mount Murray 0630 - 0930 and 1830 - 2130 Monday to Saturday inclusive and on Sundays 0700-1000hrs, 1230-1530 hrs and 1900-2100hrs. None of these sites is accessible by foot solely using footways. Unlike sports clubs, there is no existing clubhouse on site and also unlike these or established tourist accommodation centres, there is no supportable use in planning terms which the revenue from the campsite could go towards. Many sports clubs use the revenue from their temporary camp sites to improve and maintain their premises and to develop their clubs. Recreation is clearly supported in the Strategic Plan. Ballavartyn, whilst not a sporting club, has developed tourist accommodation on its site, including such which is specifically designed for disabled users which has links with the Manx Carriage Driving 4 Disabled which is based there. There are no facilities on site for wet weather - clothes drying or simply shelter and there are no areas of hard surfacing if the weather were inclement and the field became unusable by vehicles. This is particularly relevant given the prevailing weather during the current TT period.
6.4 As can be seen from the list of existing sites above, which is not exhaustive by any means, there are many camp sites on the Island, including a small number of permanent ones, for example in Laxey and Peel and many, many more which crop up on a seasonal basis to accommodate the additional campers who come for the various motorcycle race periods. Recent discussion with Department for Enterprise has revealed that they have undertaken a review of the amount of camp site pitches available during these periods in order to assess whether there is a need for any more. The results of this work is due to be published imminently. Until then, it is considered premature to allow any further camp sites unless they would provide something that is not already being provided and where the visitor will have a high quality experience of a quality rated camp site. Neither would appear to be the case here. The oversupply of camp/glamping/motorhome sites could result in a number of unfortunate effects including the lack of sufficient support for those permanent camp sites which have
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afforded the expense of the provision of permanent facilities, and where the partial take up of existing camp sites - permanent and seasonal would not only undermine the viability of those which in turn could result in a lack of resources to sports clubs - but could, more importantly, result in half filled camp sites which in some cases, particularly where there are motorhome pitches without any other ostensible camping infrastructure, look simply as if people had parked in a field, which is not something which the Department would or does support.
6.5 As such, whilst in the past the Department has justified setting aside the presumption against such developments on the basis that the development would support other Government strategies and other objectives of the Strategic Plan, in this case, it is not considered that such justification exists.
6.6 Furthermore, the site is immediately alongside a main road and from where, including the Ballacutchel Road, the tents, vehicles, motorhome and portable structures would be clearly visible and detrimental to the character of the area. This impact would be exacerbated if the campsite were not fully occupied, which is likely if the campsite were operational outwith the peak demand periods associated with the race events.
6.7 Visibility from the entrance from the perspective of someone in a vehicle emerging from the gate (which is different from people coming down Knock Froy Road) is around 130m in the Douglas direction but only around 40m towards Ballasalla taken to the farside kerb as there is separation of the two sides of the road by line painting and a pedestrian refuge which would dissuade motorists from crossing onto the opposite side of the road to overtake or to turn into Knock Froy Road before the pedestrian refuge. The speed of traffic here is limited to 50 mph and the flow of traffic is relatively heavy and the speed fast given that this is the main route in and out of Douglas from the south. The visibility should be 120m in both directions.
6.8 Finally, the use of the access will require the introduction of some formality to the current arrangement and this is highly likely to adversely affect the existing trees in this part of the field. This is not acknowledged in the application. These trees contribute to the character of the area and their future is not jeopardised by the legitimate use of the field for agricultural or grazing purposes. In addition, to be suitable for motorhomes, it is likely that there may be a requirement for additional areas of hardstanding which would not only be inappropriate in a rural field but also would prejudice the proper use of the field for agricultural or equestrian purposes.
CONCLUSION 7.1 The proposal is considered to be contrary to the land use designation as not for a particular purpose and of High Landscape Value and Scenic Significance and without any demonstrable justification to set aside this policy objection and where there would be a harmful visual impact on the character and appearance of the countryside, contrary to Environment Policies 1 and 2 and General Policy 3. In addition, it is not considered that there is adequate visibility of and from vehicles emerging from the site onto the A5 which is a Principal Traffic Route and the main route into and from Douglas from the south of the Island. The proposal would have no facilities for clothes drying or wet weather accommodation or storage and finally, the increased usage of the field gate by camping traffic is likely to adversely affect the health and future of the trees in the vicinity of the entrance, to the detriment of the character of the area.
INTERESTED PERSON STATUS 8.1 By virtue of the Town and Country Planning (Development Procedure) (No 2) Order 2013 Article 6(4), the following persons are automatically interested persons: (a) The applicant, or if there is one, the applicant's agent; (b) The owner and the occupier of any land that is the subject of the application or any other person in whose interest the land becomes vested; (c) Any Government Department that has made written submissions relating to planning considerations with respect to the application that the Department considers material
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(d) Highway Services Division of Department of Infrastructure and (e) The local authority in whose district the land the subject of the application is situated.
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.
8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status. __
I 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 : Refused
Committee Meeting Date: 10.06.2019
Signed : A MORGAN 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
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