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22/00287/B
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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 22/00287/B Applicant : Department Of Infrastructure Proposal : Restoration of existing silt store to create and maintain a permanent facility for storage and monitoring of dredged material from Peel Marina Site Address : Rockmount Silt Store Poortown Road Peel
Planning Consultant: Andrew Sierakowski Photo Taken :
Site Visit :
Expected Decision Level : Planning Committee
Recommendation
Recommended Decision:
Permitted Date of Recommendation: 15.01.2026 __
Conditions and Notes for Approval C : Conditions for approval N : Notes attached to conditions
C 1. Within 12 months of this decision becoming final, and prior to the commencement of any further works on site, a Detailed Design and Programme of Works as set in in paragraph 2.4.1 of the Environmental Impact Assessment Report ("the EIA Report") dated February 2022 prepared by Anthony D Bates Partnership which is informed by the ground investigation works set out at paragraphs 2.4.2 - 2.4.5 of the EIA Report shall be submitted to and approved in writing by the Department. The Detailed Design and Programme of Works shall set out a detailed design, consistent with the concept for the restoration scheme set out EIA Report Section 2.3 and paragraph 2.4.6, and include a programme for all of the pre-restoration and restoration works set out in the EIA, including:
o Pre-restoration works to trees on access track (paragraph 2.3.13); o Pre-restoration works to Field 314574 including bund stabilisation (paragraphs 2.3.15 - 2.3.18), engineered cap (paragraphs 2.3.19 - 2.3.22), surface water drainage (paragraphs 2.3.23 - 2.3.24) and monitoring wells (paragraphs 2.3.25 - 2.3.26); o Restoration works to Field 314574 including seeding of the external face of the bund and restoration layer of the cap (paragraphs 2.3.28 - 2.3.32), planting at the dry woodland area fronting the bunded storage area (paragraphs 2.3.33 - 2.3.42), re-profiling and seeding of the field area to the North of the bunded storage area (paragraphs 2.3.43 - 2.3.46); o Pre-Restoration Works to Field 314514 comprising the decommissioning of leachate management area (paragraphs 2.3.48 - 2.3.49); and o Restoration works to Field 314514 including a wet woodland planting area (paragraphs 2.3.51 - 2.3.60) and restoration of the remainder of the field to be suitable for grazing (paragraphs 2.3.61 - 2.3.63).
The development shall be carried out in accordance with the approved Detailed Design, including approved Programme of Works.
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Reason: To ensure the submission for approval of a Detailed Design and Programme of Works, consistent with the concept for the restoration scheme set out EIA Report.
C 2. The materials used in the works shall be in accordance with the EIA Report, paragraphs 2.4.13 - 2.4.17. No waste shall be imported to the site.
Reason: To ensure the development takes place in accordance with the approved details and to protect the environment.
C 3. Prior to the commencement of any further works on site, an updated Ecological Impact Assessment, including updated surveys, shall be submitted to and approved in writing by the Department. The works shall then proceed in accordance with the approved details.
Reason: To ensure that ecological mitigation measures are updated to take account of any changes to the ecology of the site.
C 4. Restoration of the site shall be undertaken as per sections 2.3.27 - 2.3.63 of the 'Poortown Silt Store - Restoration Scheme and Aftercare Environmental Impact Assessment Report' dated February 2022, as may be required in accordance with the updated Ecological Impact Assessment to be submitted for approval in accordance with Condition 3.
Reason: for the avoidance of doubt, to ensure the development takes places in accordance with the approved details and to avoid any unacceptable environmental impacts on ecology.
C 5. Subject to any amendments arising from submission for approval of the Detailed Design and Programme of Works in accordance with Condition 1, and Conditions 3, 4 and 9, the mitigation measures set out in Table 10.1 of the EIA Report shall be fully implemented, and as part of this:
o any works to the construction track shall be undertaken in accordance with the mitigation measures set out at paragraphs 2.4.7 - 2.4.8; o the mitigation measures set out in paragraphs 6.3.8 - 6.3.10 shall be fully implemented; and o the mitigation in relation to vehicle movements as set out in paragraphs 8.3.21 - 8.3.29 and 8.3.37 shall be fully implemented.
Reason: for the avoidance of doubt, to ensure the development takes places in accordance with the approved details and to avoid any unacceptable environmental impact including in relation to trees, ecology or highways.
C 6. Prior to the commencement of any further works on the site an Arboricultural Method Statement (AMS), adhering to the recommendations of BS 5837:2012 (Trees in relation to design, demolition and construction - recommendations), shall be submitted to and approved in writing by the Department. The AM'S should address
(a) The specification of the protective fencing to be used (B) Removal of existing structures and hard surfacing (c) The installation of temporary ground protection (d) Excavations for utilities (e) The installation of new hard surfacing and raised levels (f) Preparatory works for new landscaping (g) How the project arboriculturist and/or construction manager will carry out arboricultural site monitoring, including a schedule of specific site events requiring input or inspection
The agreed protection measures and construction methods shall adhered to in full
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Reason: to provide a level of technical detail sufficient to provide a high level of confidence in the outcome for retained trees on the site.
C 7. No retained tree shall be cut down, uprooted, destroyed, pruned, cut or damaged in any manner during the pre-restoration and restoration phases of the development hereby approved and thereafter within 5 years from the date of completion of the restoration works, other than in accordance with the approved plans and particulars. In the event that trees marked for retention die or become damaged or otherwise defective prior to, during or within 5 years following completion of the restoration works and this is due to events outside the applicants control, the Department shall be notified as soon as reasonably practicable and remedial action shall be carried out in accordance the details which have first been approved in writing by the Department.
Reason: Required to safeguard and enhance the character and amenity of the area, to provide ecological, environmental and bio-diversity benefits and to maximise the quality and usability of open spaces within the development, and to enhance its setting within the immediate locality.
C 8. No approval is hereby given for the removal of any trees as part of the pre-restoration works other than as set out at paragraph 2.3.13 of the EIA Report.
Reason: To ensure that no other trees are removed that would require consent under the Tree Preservation Act 1993.
C 9. The development shall be carried out in accordance with the mitigation measures set out in the EIA Report, paragraphs 8.3.21 - 8.3.30 and paragraphs 8.3.37- 8.3.38.
Reason: To ensure the development takes place in accordance with the approved details and in order to regulate HGV movements on the public highway.
C 10. The site will be subject to the aftercare arrangements as set out at the EIA Report, paragraphs 2.5.1 - 2.5.17.
Reason: To ensure the development takes place in accordance with the approved details in order to protect the environment.
C 11. Not withstanding the provisions of the Town and Country (Permitted Development) Order 2025 (or any order altering or replacing that order) no operational development may take place without the benefit of a specific planning application.
Reason: such development may impact on the restoration scheme and result in unintended environmental impact.
This application has been recommended for approval for the following reason. The retention of the existing deposited material on the site, is considered to be the best available option, for which there is a clear need and for which there is no immediately obvious and available alternative. As such it can be considered that the case is made that there is an acknowledged need, taking into account whether there are any potential alternatives in accordance with The Isle of Man Strategic Plan 2016 Waste Policy 1 and General Policy 3, insofar as there is an acknowledged need for the proposal in accordance with the approved Waste Management Strategy in providing void space for what is a problematic waste, and an overriding national need that justifies development outside allocations insofar as there is no reasonable and acceptable alternative. The main considerations then are whether the proposal is acceptable in terms of it environmental impacts. The proposed development's impacts on ecology, traffic, noise, air quality the water environment (i.e. surface water quality and groundwater quality), on landscape character and views, and on climate, can be addressed by the proposed mitigation measure included in the proposal. The application can accordingly be
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considered to be compliant with The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, General Policy 3, and Environment Policies, 1,2, 7, 22 and 28.
Plans/Drawings/Information;
This decision relates to the following plans/drawings/information:
o Application Form, dated 09.03.22 o Cover Letter, dated 09.03.22 o Environmental Impact Asessment Report dated February 2022 prepared by Anthony D Bates Partnership, including appendices:
Updated Statement headed "Management of sediment from Peel Marina" and Update on the Environmental Impact Assessment Report received on 25.11.2025 o The Drawings Appendix A comprise:
Dated 26-Jan-2022)
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Interested Person Status
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It is recommended that the owners/occupiers of the following properties should not be given Interested Person Status as they are not considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
Sea Peep Poortown Road Peel - as they do not clearly identify the land which is owned or occupied which is considered to be impacted on by the proposed development in accordance with paragraph 2A of the Policy. __
Officer’s Report
THIS APPLICATION IS REFERRED TO THE COMMITTEE AS IT REQUIRED TO BE ACCOMPANIED BY A FORMAL ENVIRONMENTAL STATEMENT
1.0 THE SITE
1.1 The site extends to approximately 3.8 hectares of what was previously agricultural grazing land located two miles (1.6km) south east of Peel and comprises the existing Poortown Silt Store, which is located in fields 314574, 314514 and 312154 immediately to the north of the Poortown Road. The silt store was first developed in 2015 to take the silt dredged from the Peel Marina.
1.2 The land owned by the Department of Infrastructure (DOI) and is situated to the immediate south east of the DOI operated Poortown Quarry.
1.3 There is a small stream that flows through the lower (southern) end of field 314514 adjacent to the A20. This stream is a minor tributary to the River Neb and receives storm water run-off from the A20 and the leachate effluent that is discharged from the silt store. The stream discharges into the River Neb approximately 1.3km to the southwest of the silt store.
1.4 Access to the site already exists via a track that bisects fields 314574, 314514. The part of the site to the west of the track is where the main silt store facility has been constructed. The store comprises a bunded area lined with a membrane and a drainage system for effluent (pipes and settlement ponds). Interim restoration and aftercare was implemented following deposit of the material in the summer of 2015. The works included a temporary capping of the dredged material, maintenance works to stabilise the bund, and decommissioning works to remove redundant site infrastructure. The dredged material was capped by covering it with a layer of site-won soil/topsoil and then seeded. The purpose of this work was to temporarily contain the dredged material and to reduce the potential for an unacceptable risk of danger to public health, pollution of controlled waters, or risk of environmental hazard (e.g. leachate generation) while the DOI sought a cost-effective and environmentally acceptable final disposal option for the dredged material.
1.5 The site currently comprises a bunded storage area, surface water and leachate management systems and an access track and parking area. The material within it is largely comprised of fine-grained, inorganic particulate matter which contains elevated concentrations of metals including lead and zinc and to a lesser extent of some polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs). The elevated concentrations of some of the metals has meant that the dredged material has been classified as 'hazardous waste'.
2.0 THE PROPOSAL
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2.1 The application is for the restoration of the existing silt store to create and maintain a permanent facility for storage and monitoring of dredged material from the Peel Marina, that is already on-site. The application was submitted in June 2022, but determination has been deferred, while a strategy for the long-term on-going management of the dredged material from the Peel Marina, has been developed, to enable the decommissioning of the temporary lagoon facility at Glenfaba Road in Peel and the remediation of the Cross Vein Mine. The proposals for these have come forward as separate planning applications.
2.2 Planning Permission for the use of the site as a temporary silt storage (Planning Approval 15/00447/B) was first approved in August 2015 and expired on 25th August 2020. The DOI initially submitted Planning Application Ref. 20/00837/B, in July 2020 for the restoration of the site to create and maintain a permanent facility for storage and monitoring of dredged material from Peel Marina. Following the consultation on that application a number of requests for additional information were received from consultees, as a result of which the application was withdrawn and the current application submitted with an Environmental Impact Assessment. The application now proposes the restoration of existing silt store to create and maintain a permanent facility for the storage and monitoring of dredged material from Peel Marina that is already on-site, but does not seek to deposit any additional dredged material from Peel Marina, i.e. the application seeks only to permanently retain the already deposited material and implement a restoration scheme.
2.3 The covering letter accompanying the planning application explains that:
"...the Planning Approval for the temporary storage of dredged silt at the Rockmount Silt Store (Planning Approval 15/00447/B) expired on 25th August 2020. The Department submitted a planning application in July 2020 to convert the silt store into a permanent storage facility (Planning Application 20/00837/B) and following the consultation period, a number of requests for additional information and changes to the proposed works were received. Following a period of consultation with DEFA Environment Directorate, the proposed works have been altered to address the points raised and additional information provided. For clarity, the Department requests that Planning Application 20/00837/B is withdrawn and a new application is enclosed which includes an Environmental Impact Assessment detailing the proposed works, the environmental arrangements for the site, together with the arrangements for site restoration and aftercare. As with our previous application (20/00837/B), the Department is not seeking to deposit any additional dredged spoil within the facility".
2.4 The application form confirms that full approval is sought and the proposal is retrospective (since 26th August 2020). The proposal will not create or alter vehicular or pedestrian access to a highway, or alter/provide any additional services. It will result in a change in site levels. It lies within 9m of a water course and close to trees, but is not located within an area of flood risk.
2.5 The application is supported by an Environmental Impact Assessment (EIA) Report which contains sections on the Project Description, EIA Methodology, the Consideration of Alternatives, and Topic Chapters (on Water Environment, Ecology, Landscape and Visual Impact, Traffic, Noise and Air Quality and Climate). It is accompanied by the following appendices:
H - Arboriculture Impact Assessment;
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J - Traffic monitoring data for the A20 Poortown Road.
Proposed Works
2.6 The proposed works will include pre-restoration works (tree pruning, bund stabilisation, capping, improving surface water drainage, installing monitoring infrastructure and decommissioning redundant infrastructure) and restoration works to prepare the site for a agricultural/nature conservation end use. Monitoring is also proposed against surrender criteria to demonstrate that there is no longer term risk in terms of leachate, gas or stability.
2.7 The proposed works are set out in detail in the EIA Report. Of particular note is that proposed end uses are nature conservation and agricultural, with the pre-restoration and restoration works being conceptual at time of writing of the EIA Report and there is potential for tree removal/pruning works, partly to facilitate access for the restoration works. The proposed restoration scheme has the following objectives,
"Containment of the dredged material to prevent unacceptable risk(s) of danger to public health, pollution of controlled waters, or risk of an environmental hazard. Improvement of site conditions to facilitate the silt store's future nature conservation and agriculture end-uses. Installation of monitoring infrastructure to monitor for unacceptable risk(s) against agreed surrender criteria" .
2.8 The silt store includes a bund at the southern end of Field 314574 within which the deposited dredged material is contained. This forms a substantial embankment on the north side of the A20 Poortown Road, although this is largely screened by the intervening tree belt. The EIA Report describes in more detail the works including:
o Pre-restoration works to trees along the access track; o Pre-restoration works to Field 314574 including bund stabilisation, an engineered cap, surface water drainage and installation of monitoring wells (for groundwater and leachate monitoring); o Restoration works to Field 314574 including seeding of the external face of the bund and the restoration layer of the cap, planting a dry woodland area fronting the bunded storage area, the re-profiling and seeding of the field area to the North of the bunded storage area; o Pre-Restoration Works to Field 314514 comprising the decommissioning of leachate management area; and o Restoration works to Field 314514 including a wet woodland planting area and restoration of the remainder of the field to be suitable for grazing.
2.9 The EIA Report sets out that a detailed design for the works will be produced (if approval is granted) which is informed by ground inspection works and will include:
o "Re-grading (shallowing) the slope gradient of the bund's external face to approximately 1 in 2 and reducing the bund's crest height accordingly, and installing geo-grid webbing, in order to achieve an acceptably low long-term stability risk, and to facilitate restoration; o Installing an engineered cap comprising a low permeability mineral layer, drainage layer and restoration layer in order to achieve an acceptably low long-term leachate generation risk, and to facilitate restoration; o Installing new surface water drainage and improving existing surface water drainage in order to achieve an acceptably low long-term stability risk and leachate generation risk, and to facilitate restoration; o Installing groundwater monitoring wells in order to achieve an acceptably low long-term stability risk and leachate generation risk, and to facilitate restoration;
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o Decommissioning redundant leachate management infrastructure in order to facilitate restoration; and o Restoring the silt store in order to achieve nature conservation and agriculture end uses".
2.10 The EIA report sets out more detail in relation to:
o Construction Works on the Access Track; o Construction Works in Field 314574; o Construction Works in Field 314574; o The Construction Materials; o Construction Programme; and o Aftercare Arrangements, including monitoring.
2.11 The EIA Report's overall findings are,
"10.1.2 The proposed development causes a minor adverse impact on ecology largely due to the potential for pre-restoration and restoration works to destroy, damage and/or disturb the habitats and species associated with the species-rich ground flora, veteran trees and PRFs, and bird nesting areas at and around the silt store. These impacts are considered significant and require mitigation. Impacts on habitats and species require mitigating through a series of measures including the use of steel plates (or equivalent) to protect ground flora and soil, restrictions on tree branch removal to protect PRFs for bats, advanced clearance of saplings and scrub to protect nesting birds, and limited excavations to protect tree roots.
10.1.3 The proposed development causes minor adverse impacts on traffic, noise and air quality along the local road network (i.e. the A20 Poortown Road) largely due to the truck movements associated with the delivery of construction materials and construction plant to the silt store. These impacts are temporary but considered to be significant and require mitigation. Impacts on traffic, noise and air quality require mitigating through the implementation of a Construction Traffic Management Plan (CTMP). Successful implementation of the mitigation measures should result in negligible adverse residual impacts and, therefore, insignificant residual impacts on traffic, noise and air quality.
10.1.4 The proposed development's impacts on the water environment (i.e. surface water quality and groundwater quality), on landscape character and views, and on climate, are largely addressed by mitigation embedded within the proposed development. These impacts do not require additional mitigation"
3.0 PLANNING POLICY
3.1 The relevant Local Plan remains the Isle of Man Planning Scheme (Development Plan) Order 1982, under which the site is not designated for development, although the land immediately to the west of the site, comprising the Poortown Quarry, is designated as an area of surface mineral working. The site lies within an Area of High Landscape or Coastal Value and Scenic Significance. There is a band of Woodland runs alongside the boundary with the Poortown Road, to the immediate south of the site road which confers Registered status on the trees within the designated area.
3.2 The Isle of Man Strategic Plan 2016 contains a number of policies that are relevant to the determination of the application, the most relevant of which is Waste Policy 1 which is set out in full below:
Waste Policy 1: Waste management installations, including landfill sites, civic amenity sites and facilities for the bulking up, separation, recycling, or recovery or materials from waste will be permitted provided that:
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(a) there is an acknowledged need for the proposal in accordance with the approved Waste Management Strategy; (b) there is no unacceptable adverse impact on local residents in terms of visual amenity, dust, noise, or vibration or as a result of the traffic generated thereby; (c) there would be no unacceptable adverse effect on: i. landscapes, geology/geomorphology and features of special interest or attraction; ii. Ancient Monuments or their settings; iii. Registered Buildings or their settings, or features of architectural importance; iv. the character and appearance of Conservation Areas; v. sites of archaeological interest; vi. sites containing species or habitats of international, national or local importance; vii. land drainage and water resources; viii. areas of woodland or the Island's timber resources; or ix. designated National Heritage Areas. (d) the proposal is acceptable in terms of access arrangements and highway safety; (e) in the case of landfill sites working shall be in accordance with a phased scheme of restoration and landscaping; (f) the proposal does not sterilize other significant mineral deposits; and (g) that the proposal will not have an unacceptable adverse impact on airport safety by, for example, increasing the risk of bird strike.
Landfill will only be permitted where it can be demonstrated that there is no alternative method for managing that waste. An application involving the installations or facilities referred to in this Policy will require the submission of an Environmental Impact Assessment.
3.3 Other relevant policies are set out below
o Strategic Policy 4, which states that "Proposals for development must...protect or enhance the landscape quality and nature conservation value of ...rural areas...and o not cause or lead to unacceptable environmental pollution..". o General Policy 3, which allows for development outside allocations including, "g) development recognised to be of overriding national need in land use planning terms and for which there is no reasonable and acceptable alternative". o Environment Policy 1, which protects the countryside and states, "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". o Environment Policy 2, which indicates that within AHLV, "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". o Environment Policy 3, which states that "Development will not be permitted where it would result in the unacceptable loss of or damage to woodland areas, especially ancient, natural and semi-natural woodlands, which have public amenity or conservation value". o Environment Policy 7, which states that development that may impact on watercourses must set out amongst other things, "...(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...". o Environment Policy 14 seeks to protect the best and most versatile agricultural land unless over-riding need and no alternative, lower quality land. o Environment Policy 22 seeks to prevent pollution, including to water or air. o Environment Policy 24 indicates where Environmental Impact Assessments may be required.
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o Environment Policy 28 which states that "development which would ... increase the risk from ground instability elsewhere will not be permitted unless appropriate precautions have been taken".
4.0 OTHER MATERIAL CONSIDERATIONS
Legislation
4.1 The Environmental Impact Assessment (EIA) Report sets out the legislative and policy framework, which includes highlighting the provisions of the:
o Public Health Act (Waste Licensing) o Collection and Disposal of Waste Regulations (2000) o Waste Strategy (2018)
Policy/Strategy/Guidance
4.2 The Isle of Man Landscape Character Assessment Update 2025 (published by the Cabinet Office) identifies the site as falling within the D1: Western Farmlands Landscape Character Area (LCA) of the Lowland Slopes and Glens Landscape Character Type (LCT).
4.3 The Assessment describes the Lowland Slopes and Glens Landscape Character Type as occurring in the west, east and south of the Isle of Man, between the uplands and the coast. It comprises rolling slopes interrupted by sudden and steeply incised glens. It is generally productive and well-settled, and contains many farms, hamlets and larger settlements.
4.4 Most of the land is farmed (predominantly pasture with some arable) but there are also patches of forestry, small reservoirs, estates with parkland planting, woodland blocks, and winding stream corridors. The fields form an expansive patchwork pattern, like a chequered quilt spread over the landscape which allows the underlying topography to show through. Most fields are bounded by Manx hedges, often topped with gorse, which stand out from the green or brown of the surrounding fields.
4.5 The Assessment states in terms of strategy that "Trees (woodland, riverside trees, avenues, parkland trees, curragh, shelter belts and hedgerow trees) should remain an important feature in the landscape. New trees should be planted to replace those reaching maturity or lost through disease, and woodlands and trees should be connected to form habitat networks" and it sets out the following as recommended planning and landscape management guidelines for the Lowland Slopes and Glens LCT:
o Protect the remaining semi-natural habitats interspersed throughout the agricultural o Landscape; o Manage meadow, verge, curragh and riparian habitats, seeking to connect them to o create strong habitat links; o Manage farmland, retaining the strong existing pattern of hedges, Manx hedges and stone walls. Seek to repair field boundaries like-for-like to retain the distinctive landscape pattern; o Manage woodland, aiming for age and species diversity. Seek to expand and link woodland habitats, but avoid planting woodland with straight edges which will conflict with the rolling landform; o Promote native deciduous tree planting to expand and link woodland and riparian habitats. Trees should follow the existing patterns in the landscape and woodland blocks should not usually have straight edges; o Seek opportunities (for example through Biodiversity Net Gain) to expand semi-natural habitats, and to restore traditional land management techniques with high biodiversity value, such as traditional hay meadows;
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o Work with farmers on alternative farming techniques to enhance biodiversity and bioabundance, minimise soil loss, and reduce agricultural run-off into rivers and groundwater; and o Seek opportunities to experiment with natural colonisation of tree and scrub cover, particularly in higher and less productive areas such as the peripheries of the uplands.
4.6 Other relevant Strategies and Policies include:
o Harbour's Strategy (2018) in relation to Harbour refers to the need for drafting options for the longer term solution for the disposal or treatment of contaminated silt. Statement 5 in the Strategy states:
Working in consultation with DEFA, the Department will determine both short- term and short- to-medium term options for the removal of the current build-up of contaminated silt in order to be able to dredge in Peel in 2018 and 2019, whilst also considering a longer-term solution for the disposal or treatment of contaminated silt. The Department will consult with other departments, Peel Town Commissioners and harbour users.
o Waste Strategy (2018) aims to manage waste sustainably and economically, with a focus on self-sufficiency and the Waste Hierarchy. It includes a Core Strategy with principles and key policies approved by Tynwald, an Annual Statement of Need to identify waste management capacity shortfalls, and a series of contemporary technical reports to support the strategy. It identifies that the priorities for waste infrastructure include provision of strategic disposal capacity including landfill void space for problematic and inert waste. The Strategy does not include explicit reference to the Rockmount Silt Store. The DOI has recently consulted on updated principles for the Waste Strategy for the period 2025 to 2035. The Strategy does not include explicit reference to the Rockmount Silt Store.
4.7 The EIA also notes that:
DEFA's Environment Directorate has indicated an emerging policy approach that will seek to apply UK standards as good practice and to transition the Island's waste management facilities from 'dilute and disperse' landfills to appropriately engineered landfills (paragraph 3.4.1).
5.0 PLANNING HISTORY
5.1 Planning Permission Ref. 15/00447/B for the Construction of a facility for the temporary (maximum 5 years) storage of dredgings from Peel Marina was approved by the Council of Ministers on 26th August 2015 subject to six conditions as summarised below:
o Condition No. 1: Within 5 years site will be restored and capable of agricultural use; o Condition No. 2: A remediation scheme is to be provided prior the site ceasing to be used; o Condition No. 3: The approved scheme must be implemented and a verification report produced; o Condition No. 4: If contamination is found, then proposals for remediation must be submitted for approval and implemented; o Condition No.5: No additional material is to be deposited on the site; and o Condition No. 6: Within 3 months a detailed tree survey is to be submitted before any trees removed/damaged and the proposed planting works undertaken.
5.2 It appears that Condition No. 6 was not complied with.
5.3 The report on the application was prepared by Planning Inspectors, whose assessment noted that:
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o there was a clear need for the dredging and disposal of material; o no alternatives were identified, with there being clear concerns with Wrights Pit North and (on the basis of timescale) practical issues with Turkeylands; and o in relation to the suitability of the site, that there would be a negative landscape impact and impact on trees, but also that there were no archaeological concerns, no residents in close proximity, no impact on water resources, some improvement in local drainage, no unacceptable impacts in relation to farmland, and no sterilisation of mineral resources or risk of birdstrike.
5.4 The Inspector identified landscape impact and impact on residents along the haul road as the key impacts. In particular he noted that the "temporary erosion of the local countryside and its landscape". He nevertheless concluded that the need outweighed these impacts.
5.5 Planning Permission Ref. 15/00447/B expired on 25th August 2020. The DOI submitted Planning Application 20/00837/B in July 2020 to convert the silt store into a permanent storage facility and following the consultation period, a number of requests for additional information and changes to the proposed works were received. Planning Application 20/00837/B was subsequently withdrawn with the current application submitted in 2022 which has included an Environmental Impact Assessment detailing the proposed works, the environmental arrangements for the site, and revised details of the proposed arrangements for site restoration and aftercare.
5.6 There are now also two other concurrent but separate planning applications in relation to the ongoing management of the silt from Peel Marina; Planning Application Ref. 24/00301/B submitted by the DOI, for the ongoing operation and decommissioning of the temporary lagoon facility for dewatering and storing sediment dredged from the marina, at Glenfaba Road in Peel; and Planning Application Ref. 25/90698/B submitted by the Department of the Environment, Food and Agriculture (DEFA) for the transport of sediment from the Peel silt lagoon to Cross Vein Mine, for treatment and use in remediation of the mine. Although both applications are linked to this application, neither is directly relevant to the determination of this application.
6.0 REPRESENTATIONS
German Parish Commissioners (12.07.22)
6.1 Have confirmed that the Commissioners have no objection to the application.
DOI - Highway Services (28.06.22)
6.2 Note that the proposal will involve the permanent disposal of the dredged material currently deposited and stored at the existing silt store, a restoration scheme and aftercare activities, and that as result no change to vehicle access, routing and internal site circulation and parking are expected.
6.3 They comment that there will be some material change to the use of the local highway network for a limited period with some additional material being transported to the silt store for the pre-restoration and restoration works, and occasional traffic movements during the aftercare period.
6.4 The deliveries will involve approximately 3,520 tonnes of construction materials comprising fine-grained and granular materials for the restoration scheme which will take place over a period of 20 days, and involve the use of two, three and four-axle rigid tipper lorries with load capacities ranging from 14 tonnes to 18 tonnes, and with an average load capacity of 16 tonnes per trip. Typically, lorry movements will occur throughout the working weekday with on average of 11 lorry movements being generated, equivalent to 22 two-way movements per day bringing, daily, 176 tonnes of construction materials. Additionally, there would be extra
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trips associated with the delivery of other construction materials, e.g. pipes, geotextiles and construction plant, e.g. excavators. These will take place over 20 days and will comprise lorry movements in various sizes of vehicle. Typically, there is predicted to be one lorry delivering construction materials and/or construction plant per day, equating to 2 two-way movements per day. In combination, there could therefore be 12 lorries (24 two-way movements) delivering construction materials and construction plant per day.
6.5 In total they advise that the trip generation associated with the restoration scheme will to take place on weekdays over a period of 40 to 60 days, and will comprise cars, vans, pick-up trucks and other light goods vehicles capable of transporting site staff and visitors. Typically, the light vehicle movements will occur at the start and end of the working day equivalent to six light vehicles or 12 two-way movements per day every day for the duration.
6.6 The maximum trip generation associated with the restoration scheme will comprise the combined traffic movements consisting of truck movements and light vehicle movements equivalent to 18 trips per day or 36 two-way movements per day.
6.7 They advise that there would be little evident impact in terms of total volume of traffic, but there is likely to be a material increase in percentage terms of lorries, such that there would be a predicted increase of 36 vehicle movements on a total of 3,104 vehicles per day, equivalent to just over a1% uplift.
6.8 The composition of traffic associated with lorry movements at certain times would increase by 31% or 24 lorries on the surveyed 78 vehicles. This would exceed the capacity of the local highway network's links and junctions suggesting an adverse impact on the local highway network.
6.9 To mitigate this impact the Applicant proposes the preparation of a Construction Traffic Management Plan (CTMP) to manage transport activities, including operating hours. Highways Services advise that this would be a satisfactory approach given that activities would be of limited duration, with some of the imported material being sourced from adjacent Poortown Quarry. They nevertheless comment that the increase in larger and heavier vehicle movements could have an impact on the condition of the route and they therfeore advise that a before and after monitoring of the road condition should be included in the CTMP. They advise that the scope and submission of the CTMP can be secured through an appropriately worded condition.
6.10 On This basis Highway Services advise that they consider the proposal to be acceptable.
DOI - Highways Drainage (08.07.22 and 16.09.22)
6.11 Have advised that they are satisfied that there will not be an increase in surface water runoff from the site onto the public highway.
DEFA - Forestry, Amenity and Lands (23.12.26)
6.12 Have advised that further clarification about the proposed level changes, infrastructure and utilities proposed on the site is required, if the application is approved. This can be addressed by condition requiring the submission for approval of Arboricultural Method Statement. They have also requested the inclusion of a condition to subsequently ensure that the works are undertaken in accordance with the approved details, so as to prevent any cutting down, uprooting, or damaged to any of the retained trees.
DEFA - Inland Fisheries Policy Manager (27.06.22 and 12.07.22)
6.13 Advises that DEFA Fisheries have no concerns in relation to the development from a fisheries perspective, provided that there is no adverse effect on the adjacent watercourse.
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They consider that this should not be the case as the aim of the development is not to disturb the contaminated site and the works aim to reduce any possible leachate from contaminating the nearby watercourse, known to contain fish populations.
DEFA - Environmental Protection Unit (23.01.25 and 17.12.25)
6.14 The Environmental Protection Unit (EPU) advises that it has taken advice from external consultants in respect of issue of a Waste Disposal Licence or Direction under s.64 of the Public Health Act 1990, that will also be required for the works for the which the planning application has been submitted. The consultants comments are set out in a lengthy report. They advise that before issuing a Waste Disposal Licence or Direction the EPU will be requesting the DOI address the recommendations set out on the consultant's report. In summary outstanding issues include:
o Undertaking analysis of the waste deposited so it can be classified to determine the appropriate design of the landfill; o Submission of a Hydrogeological Risk Assessment (HRA) to characterize more fully the groundwater levels, flow direction, groundwater and leachate quality; o Provision of a detailed design for the containment bund to address stability concerns; o Submission of a Landfill Gas Risk Assessment; o Clarification of the borehole, leachate monitoring proposed and leachate flow direction; o Details of Licence surrender criteria for specific contaminants of concern.
6.15 Until these issues are clarified the EPU has advised that a Waste Disposal Licence or Direction cannot be issued.
6.16 In response the DOI (as the applicant) have advised that the project is been taken forward in two phases, with Phase 1 being to secure approval of this planning application before the Phase 2 detailed design can be undertaken, taking into account all the details requested by the EPU's consultants, with the detailed design information being submitted as part of the Waste Disposal Licence/Direction application, and the works on the site completed within two years.
6.17 DOI have in response to the summary points set out above advised (both in the planning application and through additional correspondence) that:
o The analysis of the waste deposited shows this to comprise inert and stable non- reactive hazardous waste, which is classed a non-hazardous; o In relation to the need for a Hydrogeological Risk Assessment (HRA), they advise that a ground investigation will be undertaken to inform the detailed design. It is intended that the results of the ground investigation will be used to update the initial HRA submitted with the planning application, with respect to geological and hydrogeological conditions and leachate risks, and the updated HRA will be used to inform the leachate management (and monitoring) measures incorporated into the detailed design, including leachate monitoring to be undertaken during the aftercare period; o In relation to the stability of the bund, a ground investigation will be undertaken to inform the detailed design. It is intended that the results of the ground investigation will be used to update the existing Geotchnical report submitted with the Planning Application in relation to bund stability and waste settlement conditions, and the updated Stability Risk Assessment will be used to inform the stability risk management measures incorporated into the detailed design of the reworked bund (including the bund slope, bund crest level); o In relation to the Gas Risk Assessment a ground investigation will be undertaken to inform the detailed design. It is anticipated that the waste contains only limited organic matter, is biologically stable and that gas risk is low, although gas monitoring will be undertaken during the aftercare period;
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o In relation to leachate monitoring it is proposed that six boreholes will be installed as part of the ground investigation required to inform the detailed design. These monitoring wells will remain in place for as long as necessary to facilitate leaching monitoring against surrender criteria; and o That surrender criteria for specific contaminants will be considered.
6.18 The EPU have subsequently confirmed that if the planning application is approved, this should be subject to conditions to ensure submission of the details recommended in the consultant's report.
DEFA - Minerals And Properties (13.07.22)
6.19 Have confirmed that they have no comment on the application.
DEFA - Ecosystem Policy Team (22.12.25)
6.20 Have advised that they have no objection to the application, although because of the length of time since the application was originally submitted the information contained in the Ecological Impact Assessment included with the application needs to be updated with a the survey and results from a new site walkover and up to date records, to determine whether the findings and mitigation recommendations of the existing assessment are still valid or need to be updated. Accordingly, they recommend that inclusion of a condition to ensure that works do not commence until an updated Ecological Impact Assessment has been submitted and approved in writing, with the work then to be undertaken in accordance with the recommended mitigation measures, and a further condition to ensure that the site is restored in accordance with the details (set out in paragraphs 2.3.27 - 2.3.63) of the Poortown Silt Store - Restoration Scheme and Aftercare EIA Report, dated February 2022.
DEFA - Environmental Health (30.12.25)
6.21 Have expressed concern that if the site were not to be managed properly there could be risk of contamination to neighbouring land that could constitute a statutory nuisance. They note that s.64 of the Public Health Act 1990 effectively exempts the DOI from the requirement to obtain a Waste Disposal Licence. Instead, they are required to ensure that the land is used in accordance with conditions which are calculated to prevent its use from causing pollution of water, danger to public health and serious detriment to the amenities of the locality in which the land is situated; and specified in a Direction given by the DEFA in accordance with the further provisions given in that s. 64 of the Act. Acordingly, they request that if approved the permission includes a condition specify that the DOI undertake groundwater/leachate monitoring and a condition that requires the DOI to adhere to the conditions of any Direction issued by the DEFA.
Manx National Heritage
6.22 Were consulted on 21st June 2022 but have not commented on the application.
Local Residents
6.23 Sea Peep Poortown Road Peel - neither supports or objects to the proposals but refers a number of sections of text in the submitted EIA Report including the text stating that the proposed development is needed in the absence of a cost-effective, available alternative for the final disposal of the dredged material and that disposal at sea was considered and ruled out by the DOI in 2015 due to the elevated contaminant concentrations in the dredged material.
6.24 The comment also notes that at the time submission in 2022 that re-use for environmental enhancement at the site of the former Cross Vein Mine was considered and
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ruled out by the DOI and the DEFA due to costs associated with this option; particularly costs associated with stabilising and transporting the dredged material from the Peel Marina.
7.0 ASSESSMENT
7.1 Main Issues
7.1.1 The main issues in the determination of the application are:
o Need/Alternatives; o The Water Environment; o Landscape/Visual Impact o Trees/Ecology; o Highway Impacts; and o Other Matters (Land Stability, Loss of Agricultural Land, Climate Change etc.).
7.1.2 It should be noted that neither covenants nor procedural matters are material planning considerations.
7.2 Need And Alternatives
7.2.1 Need and alternatives are the substantive policy requirements with The Isle of Man Strategic Plan 2016 Waste Policy 1 and General Policy 3 respectively setting out that there must be an acknowledged need for the proposal in accordance with the approved Waste Management Strategy and that for development outside allocations there is an overriding national need for which there is no reasonable and acceptable alternative.
7.2.2 The background to the application is that periodic dredging has had to be undertaken at Peel Marina for a number of years due to the build-up of sediment deposited in the marina from the River Neb catchment, but potentially also includes sediment derived from the sea. The build up of sediment reduces safe depths for commercial vessels and restricts access to berths. In 2015, the DOI constructed the Poortown Silt Store to receive and temporarily store the dredged material from Peel Marina because of the lack of an alternative disposal facility.
7.2.3 The key problem, that the Environmental Impact Assessment submitted with the application identifies is that the dredged material consists of fine-grained, inorganic particulate matter and contains elevated concentrations of some metals (notably lead and zinc) and, to a lesser extent, elevated concentrations of some polycyclic aromatic hydrocarbons (PAHs) and polychlorinated biphenyls (PCBs). The elevated concentrations of some metals meant that the dredged material has been classified as 'hazardous waste'.
7.2.4 The source of the heavy metal contamination in the marina sediment has been identified as deriving from several metalliferous mines located within the River Neb catchment including the Cross Vein Mine located approximately 9km south of Peel in South Barrule.
7.2.5 At the time of its construction in 2015, the purpose of the Rockmount Silt Store was to provide a temporary storage solution for the dredged material for a period of up to five years (i.e. until 2020). However, in the absence of a cost-effective, available alternative for a final disposal option for the dredged material, the DOI has proposed developing the silt store to enable the permanent disposal of the dredged material such that, in effect, the silt store would become a waste management facility taking the form of a landfill.
7.2.6 The proposed development is for the permanent disposal of the dredged material currently deposited and stored at the silt store, and would not involve any new deposits of dredged material or other waste types. In other words the material already deposited there would be retained on the site.
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7.2.7 The need for dredging at Peel Marina has continued and it was dredged again in 2020 and 2021 with approximately 23,000m3 of dredged sediment removed.
7.2.8 Disposal of the dredgings at sea has been considered as a potential long term option, but chemical analysis of the sediment in the marina has recorded concentrations of lead that have exceeded Centre for Environment, Fisheries and Aquaculture Science (CEFAS) Action Levels and therefore, the sediment cannot be deposed at sea.
7.2.9 The additional dredged sediment has in the meantime been stored in a temporary dewatering lagoon just the south of Peel Power Station, at Glenfaba Road in Peel, initially for a temporary period on the basis of Planning Permission Ref. 18/01293/B, that was approved in March 2019, but with the development of an ongoing and permanent disposal strategy is still required. The need for the current application has to be placed in this context and particular in relation to the question of what to do with the sediment already deposited on the site.
7.2.10 In order to make site suitable for the permanent retention of the stored silt pre- restoration and restoration works are required to ensure the stability of the bund wall on the south side of the site and to it for monitoring activities, and to restore it for nature conservation and agriculture end-uses.
7.2.11 The proposed pre-restoration and restoration works are conceptual with the concept reflecting the recommendations of a geotechnical condition assessment, stability risk assessment, a hydrogeological risk assessment, and consultation between the DOI and
DEFA's Environment Directorate. The concept is intended to provide sufficient flexibility such that the (future) detailed design of the pre-restoration and restoration works can be reserved by condition.
7.2.12 The current application addresses need (as set out above) and alternatives with the EIA report setting out the options considered and why the other options are not considered appropriate. The other options considered include disposal at sea, re-use at Cross Vein Mine, disposal at Wrights Pit North Landfill, disposal at Turkeylands Old Quarry or Turkeylands New Quarry. The reasons for discounting these options were as set out below.
o Disposal at sea was considered and ruled out by the DOI in 2015 due to the elevated contaminant concentrations in the dredged material. o Re-use for environmental enhancement at the site of the former Cross Vein Mine was considered and ruled out by the DOI and the DEFA due to the costs associated with this option, particularly costs associated with stabilising and transporting the development dredged material to Cross Vein Mine, and preparing and managing the site at Cross Vein Mine. The remediation of the Cross Vein Mine site has now been proposed and is the subject of another Planning Application, Ref. 25/90698/B, on which further detail is set out below). o Disposal at the Wrights Pit North (WPN) landfill has been considered and ruled out by the DOI due to the site being a strategic landfill facility for non-leaching, nonbiodegradable, problematic wastes, and being unsuitable (e.g. unlined and non-engineered) and not licensed to receive large quantities of hazardous dredged material. o Disposal at the Turkeylands Old Quarry (TOQ) landfill was considered and ruled out by the DOI due to the site being a strategic landfill facility for asbestos and Incinerator Bottom Ash (IBA) waste types and being unsuitable (i.e. lacking void space) and not licensed to receive large quantities of hazardous dredged material. o Disposal at the Turkeylands New Quarry (TNQ) landfill was considered and ruled out by the DOI due to the site being a strategic landfill facility for the deposit of inert wastes and maturated IBA from the Island's Energy from Waste (EfW) facility, and being unsuitable (e.g. unlined) and not licensed to receive large quantities of hazardous dredged material.
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7.2.13 More detailed consideration of the Environmental Effects of the Do Nothing Alternative (i.e. leaving in situ without any further works) and also the alternative of removing the material and restoring the site are considered in the EIA Report.
7.2.14 The conclusions of the assessment are that the proposed retention and restoration of existing silt store to create and maintain a permanent facility for storage and monitoring of dredged material is preferred over the do nothing alternative because it is predicted to have less adverse environmental effects. It also concludes that the proposed development is preferred over the relocation alternative because although it is predicted to have similar environmental effects, at the time of preparing the EIA Report (February 2022), Wrights Pit North, Turkeylands Old Quarry or Turkeylands New Quarry were either not licensed and/or did not have the void capacity to receive dredged material relocated from the silt store.
7.2.15 The EIA Report further explains the positive reasons for choosing the site for the silt store are that the site is on land owned by the DOI and adjacent to land operated by the DOI (i.e. Poortown Quarry) and because:
o the site is close to Peel Marina (i.e. approximately two miles) and, therefore, the source of the dredged material; o the site is not close to any Public Rights of Way; o the site is sufficiently sized to accommodate the silt store; o the site can be engineered to provide the necessary containment and was sloping to facilitate drainage by gravity; o the site can be screened to reduce the silt store's visibility; o the site is not known to support any flora and fauna of particular nature conservation value; and o the site drains into a local watercourse that was known to already be affected by elevated concentrations of contaminants (i.e. metals such as lead and zinc).
7.2.16 As set out above, since the submission of the current application, the strategy for the longer term management of the dredged silt from the Peel Marina has been developed further and two additional planning applications have been submitted. The first of these, Planning Application Ref. 24/00301/B is for the ongoing operation and decommissioning of the temporary lagoon facility at Glenfaba Road in Peel for the dewatering and storing sediment dredged from Peel Marina. The second application, Planning Application Ref. 25/90698/B, is for the remediation of the Cross Vein Mine.
7.2.17 The strategy involves use of the sediment currently stored in the Peel silt lagoon as remediation material at the Cross Vein Mine, and then the subsequent decommissioning and restoration of the Peel silt lagoon site. The remediation of the Cross Vein Mine is intended to reduce the contamination of waterbodies located in Peel (including Peel Marina) and the wider River Neb catchment, and ultimately to enable the development of an alternative long term sediment disposal strategy for the material dredged from Peel marina without the need to continue to use a temporary storage facility or landfill.
7.2.18 In the light of the evolving strategy for the management of the of the dredged silt from the Peel Marina, The applicant, the DOI, has been asked to update the EIA Report in relation to the consideration of the Need and Alternatives.
7.2.19 In response to the request, the DOI has advised that the updated strategy assumes that the Planning Applications for Rockmount Silt Store (Ref 22/00287/B) and Peel Marina Lagoon (Ref 24/00301/B) and DEFA's application for Cross Vein Mine Remediation (25/90698/B) are all approved and implemented.
7.2.20 The strategy assumes a need to undertake further dredging to remove the build-up of sediment in the Peal Marina, which has accumulated since the previous dredging campaigns in
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2020 and 2021 and takes in account further future deposits of sediment from the River Neb in the Peal Marina at a rate of 2,000m3 per annum.
7.2.21 The strategy in the medium-term continues to assume that sediment currently in the marina is not suitable for disposal at sea, due to a number of samples indicating the levels of heavy metals (primarily Lead & Zinc) exceed the Cefas Action Level 2 threshold. Therefore, the dredged sediment will need to continue to be brought to land for reuse or disposal.
7.2.22 Between 2028 and 2032, the marina would be dredged bi-annually (on three occasions) to remove circa 12,000m3 of sediment in each dredging campaign (so 36,000m3 in total). The sediment would be dewatered in a modified dewatering lagoon before washing and screening the material to separate out the sands and gravel fractions from the silts and clays fraction. The heavy metals are generally only bound to the silt and clay fractions, with previous sediment testing indicating that approximately 65% of the sediment is sands and gravels and circa 35% silts and clays. The washed and screened sands and gravels material would be suitable for reuse, on-island (e.g. in lieu of quarried sands & gravels).
7.2.23 The DOI advise that further investigation and testing of the silts and clays fractions indicates that this can potentially also be treated and made suitable for reuse. Alternatively, the material may be treated to a level to classify it as Inert Waste for disposal in one of the island's existing Inert Waste landfills. It advises that if neither option is viable, provision has been made for dredged material to be landfilled at the proposed Strategic Waste Landfill Facility, Turkeylands.
7.2.24 The use of the existing temporary dewatering lagoon at Glenfaba Road for a washing and screening operation may require a further modification to the planning permission for the site.
7.2.25 In the long-term, options being considered by the DOI include as follows:
o The remediation of Cross Vein Mine is expected to reduce the quantity of lead particles washing into the River Neb. Further investigation will be required to determine if this, together with other measures within the River Neb Catchment (e.g. Kionslieu Reservoir outfall settlement pond) will be sufficient to reduce the levels of heavy metals entering the River Neb and subsequently found in the marina sediment below the Cefas Action Level 2 threshold or if additional measures will be required; and/or
o Creating a dedicated channel within Peel Marina to separate the River Neb from the marina may prevent sediment settling in the segregated marina area. Further work is required to assess the impacts on flooding, fisheries and marina operations, together with engineering layout options and costs.
7.2.26 In addition to the above options, the DOI has considered the trans-frontier shipment of waste as an option for the disposal of dredged material containing elevated contaminant concentrations. A study conducted in 2022 found trans-frontier shipment to be legally and technically viable, but prohibitively expensive. Consequently, the DOI has progressed the option to use the dredged material at Peel as a capping material for the remediation of the Cross Vein Mine.
7.2.27 In this context the retention of the existing deposited material on the site, is considered to be the best available option, for which there is a clear need and for which there is no immediately obvious and available alternative. As such it can be considered that the case is made that there is an acknowledged need, taking into account whether there are any potential alternatives in accordance with The Isle of Man Strategic Plan 2016 Waste Policy 1 and General Policy 3, i.e. there is an acknowledged need for the proposal in accordance with
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the approved Waste Management Strategy in providing void space for what is a problematic waste, and an overriding national need that justifies development outside allocations insofar as there is no reasonable and acceptable alternative. The main considerations then are whether the proposal is acceptable in terms of it environmental impacts.
7.3 Water Environment
7.3.1 The key issue in relation to the water environment is whether the proposal would have any unacceptable impacts on water quality, in the stream that flows through the southern end of field 314514 adjacent to the A20 and on groundwater. Relevant policy includes that set out in The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, Environment Policy 7 and Environment Policy 22.
7.3.2 The assessment of the impacts on the water environment is set out in the EIA Report (Chapter 5 - Water Environment) and a supporting Hydrogeological Risk Assessment, which consider the impact on surface water quality due to leachate discharge and the impact of the proposed development on groundwater quality and the water environment due to leachate seepage.
7.3.3 In relation to surface water and groundwater the assessment identifies that leachate discharged to the stream and seepage into the ground is not expected to have a significant effect on water quality because the dredged material has undergone physio-chemical and bio- chemical degradation and stabilisation processes, so as not to give rise to an unacceptable risk of pollution. In addition, the proposed restoration scheme, including the works to install an engineered cap (incorporating a drainage layer and a low permeability mineral layer) and to improve the surface water drainage system, should further reduce the risk of pollution. Accordingly, the discharge and/or seepage of leachate into the stream and underlying soil and ground would have a negligible impact on surface and groundwater water quality (paragraphs 5.3.18 and 5.3.21).
7.3.4 However, while the EIA report identifies that there is not therefore an unacceptable risk of pollution from leachate generation, it identifies that there is nevertheless a degree of uncertainty associated with the extent of the degradation and stabilisation of the dredged material and the performance of the silt store's liner and leachate management system and potentially, therefore, the conclusions of the hydrogeological risk assessment.
7.3.5 As result the hydrogeological risk assessment makes the following recommendations to address this uncertainty:
o The undertaking of a ground investigation of the silt store area, including installation and sampling of (ideally three) monitoring wells (i.e. one up-hydraulic gradient and two down hydraulic gradient) in order to ascertain: o geology; o geotechnical parameters; o groundwater elevation (and therefore unsaturated zone thickness); o groundwater flow direction; o hydraulic gradient; o groundwater quality; o fraction of organic carbon; and o falling head tests on the hydraulic conductivity of the underlying geology; o Additional dredged material leachate analysis for lead; and o Additional dredged material analysis for PAHs (speciated PAHs) and TPH (aliphatic and aromatic fractions).
7.3.6 In support of these recommendations the proposal includes the installation of monitoring wells and the undertaking of aftercare monitoring for water quality. The purpose of
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this monitoring is to demonstrate that the silt store is no longer capable of generating leachate that could cause environmental pollution or harm to human health. Assuming that the aftercare monitoring demonstrates a trend of maintained or improved leachate quality and, therefore, a trend of no unacceptable risk, it concludes that there would remain no more than a negligible residual impact on surface water quality and groundwater quality.
7.3.7 The EIA Report confirms that the site requires Waste Disposal Licence or Direction for the disposal and storage of waste at the silt store in accordance with the provisions of the Public Health Act 1990 and a Discharge to Water Licence from the DEFA's Environment Directorate for the discharge of drainage effluent from the silt store in accordance with the provisions of the Water Pollution Act 1993.
7.3.8 As set out above the EPU has offered detailed comment on the application based on the advice from external consultants. This is essentially concerned with matters that are of relevance to the Waste Disposal Licence or Direction, and which are to be addressed by the DOI as applicant, in developing the detailed design of the project once this planning application has been determined. This will include the undertaken of a Hydrogeological Risk Assessment (HRA) to update the initial HRA submitted with the planning application, with respect to geological and hydrogeological conditions and leachate risks, and additional ground investigation and an updated Stability Risk Assessment to inform the stability risk management measures to be incorporated into the detailed design of the reworked bund.
7.3.9 The EPU has confirmed that if the planning application is approved, this should be subject to conditions to ensure submission of the details recommended in the consultant's report.
7.3.10 DEFA - Environmental Health have similarly expressed concern that if the site were not to be managed properly there could be risk of contamination to neighbouring land that could constitute a statutory nuisance. They have accordingly requested that, if approved the permission include a condition specify that the DOI undertake groundwater/leachate monitoring and a condition that requires the DoI to adhere to the conditions of any Direction issued by the DEFA.
7.3.11 It should be noted that it is not the role of the planning system, and it should not be used, to duplicate other statutory controls including the regulation of waste disposal and emissions to water. Nevertheless, it is considered that the above points (to the extent that they relate to the planning approves) can be addressed by conditioning of the submission of the further details of the design and programme of work including monitoring to the extent that this required to make proposal acceptable as the development and use of land and to ensure that they can be effectively regulated as part of the development works.
7.3.12 The Inland Fisheries Policy Manager has advised that they have no concerns in relation to the development from a fisheries perspective, and therefore do not object to the proposal.
7.3.13 The application can accordingly be considered to be compliant with The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, Environment Policy 7 and Environment Policy 22, subject to the inclusion of conditions relating to the submission of a Detailed Design and Programme of Works (Recommended Condition No. 1) and the implementation of the mitigation proposals set in the EIA Report (Table 10.1) (Condition 5) which comprises the embedded mitigation including additional ground investigation, the installation of monitoring infrastructure, and the aftercare monitoring of surface water quality and groundwater quality against surrender criteria (Recommended Condition 1 and 5). It should be noted that the recommended conditions attached to the permission are not intended and cannot regulate the disposal of waste or discharges from the site, which will be regulated through the Waste Disposal Licence or Direction and Water Licence.
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7.4 Landscape and Visual Impact
7.4.1 The key issue in terms of the landscape and visual impacts is whether the restoration of existing Rockmount Silt Store to create and maintain a permanent facility for storage and monitoring of the dredged material on the site would have adverse impacts. A key factor in this is that the site is fairly well screened by the local topography and the surrounding tree belts and woodland.
7.4.2 As set out above site lies within an Area of High Landscape Value (AHLV), and relevant policy includes that set out in The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, Environment Policies 1 and 2. In addition, the Isle of Man Landscape Character Assessment Update 2025 sets out recommended planning and landscape management guidelines for the Lowland Slopes and Glens LCT that seek to protect the remaining semi- natural habitats and agricultural landscapes.
7.4.3 The landscape and visual impacts of the proposal are assessed in the EIA Report (Chapter 7), which focuses on the impact on landscape character and views due to the physical presence of the silt store. It concludes that:
"The proposed development will cause a minimal but permanent change to the local landscape character; particularly the landscape character of the area immediately at and around the bunded storage area in field 314574. In addition, the proposed development will cause a minimal but permanent change to views; particularly near-distance views in which the silt store is partially screened but visually discernible and identifiable (e.g. from the A20 Poortown Road), but not in middle-distance views (e.g. from footpaths) or far distance views (e.g. from Slieu Whallian). Overall, the proposed development will have a minor adverse impact on the local landscape character, a minor adverse impact on near-distance views, and a negligible impact on middle-distance and far-distance views".
7.4.4 Mitigation measures are embedded into the proposal, in the form of reducing the bunded storage area's crest height (thereby reducing its elevation above the adjacent field's contours), and vegetating the bunded storage area's external face and engineered cap. This mitigation, the EIA Report states, will soften the physical presence of the bunded storage area and reduce the impact on the local landscape character.
7.45 In addition, supplementary tree planting is proposed in the woodland between the bunded storage area and the A20 Poortown Road. This planting will screen the bunded storage area, and reduce the impact on views; particularly near-distance views.
7.46 The assessment concludes that with the mitigation implemented, there will be a negligible residual impact on the local landscape character and near-distance, middle-distance and far-distance views. Is concludes that:
"With the mitigation implemented, there will be a negligible residual impact on the local landscape character and near-distance, middle-distance and far-distance views".
7.47 The application can accordingly be considered to be compliant with The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, Environment Policies 1 and 2 and with the Landscape Character Assessment Update 2025 recommended planning and landscape management guidelines, subject to the inclusion of conditions relating to the submission of a Detailed Design and Programme of Works (Recommended Condition 1) and the implementation of the mitigation proposals set in the EIA Report (Table 10.1) comprising the embedded mitigation proposals (Recommended Condition Nos. 1 and 5).
7.5 Ecology and Trees
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7.5.1 The key issue is whether the restoration of existing Rockmount Silt Store will have any adverse impacts on the impacts on the scrub, sapling and tree habitat on and adjacent to the site.
7.5.2 As set out above the Isle of Man Planning Scheme (Development Plan) Order 1982, identifies that the site lies within an Area of High Landscape Value (AHLV), and the band of Woodland that runs alongside the boundary with the Poortown Road, which confers Registered status on the trees within the designated area.
7.5.3 Other relevant policy includes that set out in The Isle of Man Strategic Plan 2016 Waste Policy 1, and Environment Policies 1 and 2.
7.5.4 The EIA Report Chapter 6 assesses the impacts on ecology, including trees, in relation to pre-restoration and restoration works. It identifies that the pre-restoration and restoration works have the potential to affect the habitats and species, including individual trees, at and around the silt store, with works for the bund stabilisation and the engineered cap having the potential to affect nesting birds in sapling trees on the bund's external face and/or the existing interim cap's surface if the works (e.g. vegetation clearance) were to destroy, damage or disturb nestbuilding, nesting and/or egg laying and hatching. In addition, it identifies that the pre-restoration works for the bund stabilisation will affect the species-rich ground flora in the dry woodland fronting the bund if the works (e.g. construction plant access and working, construction material delivery) were to damage the ground flora and/or compact the underlying soil and, as a result, were to reduce or prevent recovery and function of damaged ground flora.
7.5.5 In addition the assessment identifies that the pre-restoration works for the bund stabilisation has the potential to affect veteran trees and potential roost features for bats if the works (e.g. soil compaction and excavation) were to damage tree roots and potentially cause root dysfunction leading to ill-health and premature death or if the works (e.g. construction plant access and working, construction material delivery) were to damage tree branches and associated potential roost features if the works (e.g. construction plant access and working, construction material delivery) were to require tree pruning. It also identifies that access to and working at the bund and on the interim cap will be unavoidable and, but that the magnitude of this aspect of the impact is assessed as low to moderate.
7.5.6 The assessment also identifies that restoration works to decommission the leachate management area has the potential to affect the habitats and species in the settlement ponds if the works were to destroy, damage or disturb sensitive species or cause increased water levels and waterlogging, although it also states that the ground flora at and around the settlement ponds is not of significant ecological interest and additional waterlogging around the trees is unlikely to occur.
7.5.7 The assessment further identifies that the impacts of the works will be partially offset by the proposed restoration scheme's planting of trees within the dry and wet woodland areas for nature conservation end-use, and proposes additional mitigation measures to address impacts on the ecological receptors in fields 314574 and 314514, including the use of steel plates (or equivalent) to protect ground flora and soil, and restrictions on tree branch removal to protect potential roost features for bats.
7.5.8 With the mitigation measures implemented successfully, the assessment concludes that there would be a negligible to minor residual adverse impact on the ecological interest at and around the silt store.
7.5.9 As set out above neither DEFA - Forestry, Amenity and Lands nor the Ecosystem Policy Team have objected to the application although both have recommended the inclusion of conditions; DEFA - Forestry, Amenity and Lands have requested the inclusions of a conditions requiring the submission for approval of Arboricultural Method Statement and a condition to
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subsequently ensure that the works are undertaken in accordance with the approved details; and the Ecosystem Policy Team have requested the inclusion of a condition to ensure that works do not commence until an updated Ecological Impact Assessment has been submitted and approved in writing, with the work then to be undertaken in accordance with the recommended mitigation measures, and a further condition to ensure that the site is restored in accordance with the submitted details.
7.5.10 In terms of the impact on ecology including trees the application can accordingly be considered to be compliant with The Isle of Man Strategic Plan 2016 Waste Policy 1, and Environment Policies 1 and 2, subject to the inclusion of conditions relating to the submission of a Detailed Design and Programme of Works (Recommended Condition No. 2) and the implementation of the mitigation proposals set in the Environmental Impact Assessment Report (Table 10.1) comprising the embedded mitigation proposals. Additional conditions are also recommended requiring the submission of an updated Ecological Impact Assessment and to ensure that the site is restored in accordance with the details set out in the EIA Report and the submission for approval of an Arboricultural Method Statement and to ensure that the works are subsequently undertaken in accordance with the approved details (Recommended Conditions 1,3, 4, 5, 6, 7 and 8).
7.6 Highway Impacts
7.6.1 The highway impacts, as set above arise from the traffic associated with the pre- restoration and restoration works.
7.6.2 Relevant policy includes The Isle of Man Strategic Plan 2016 Waste Policy 1.
7.6.3 Chapter 8 of the EIA Report assesses the traffic noise and air quality impacts of the development. In relation to traffic, the assessment considers the impact of the proposed development on the local highway network due to traffic movements and the impact of the proposed development on noise and air quality due to traffic movements.
7.6.4 As set out above the assessment identifies that the development will generate a temporary change to the number and composition of traffic movements on the A20 Poortown Road, and that the majority of the traffic movements will occur when construction materials are being transported to the silt store for the pre-restoration and restoration works. Only occasional traffic movements will occur during aftercare activities.
7.6.5 The assessment confirms that the anticipated maximum number of total traffic movements associated with the restoration scheme will not cause a discernible change to baseline traffic flows and will continue to be within the capacity of the A20 Poortown Road's links and junctions, and that the anticipated maximum number of total traffic movements associated with the restoration scheme will have a negligible impact on the local highway network. The assessment therefore concludes in relation to total traffic movements associated with the restoration scheme, "mitigation measures are required and there will remain a negligible residual impact.
7.6.6 Solely in relation to truck movements however the assessment concludes that the restoration scheme will generate a change in traffic movements on the A20 Poortown Road equating to approximately 30.8 per cent, albeit only for a limited period of time, resulting. On this basis, it concludes that the truck movements associated with the delivery of construction materials for the restoration scheme may cause a discernible change to the composition of traffic associated with truck movements and may not be within the capacity of the A20 Poortown Road's links and junctions. It therefore concludes that a Construction Traffic Management Plan (CTMP) which would set out procedures to manage transport activities should be submitted for approval prior to the commencement of deliveries. Elements of this can be conditioned as recommended above.
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7.6.7 The assessment also identifies that the impact on noise and air pollutant emissions is negligible with regard to the total traffic movements, and minor with regard to the truck movements, albeit for a temporary period during which construction materials are being delivered. These too it concludes can be acceptably managed though the traffic management the preparation and implementation of a CTMP.
7.6.8 Detailed comments from DOI - Highway Services are set out in Section 5 of this report. They advise that they agree with the assessment and recommended mitigation measures set out in the EIA Report. They have recommended the inclusion of condition requiring the submission for approval of Construction Traffic Management Plan (CTMP), however this could lead to the inclusion of measures which may be difficult to enforce through the planning process and so it proposed to instead to include a condition requiring the implementation of the construction traffic mitigation measures set out in the EIA Report, paragraphs 8.3.21 - 8.3.30 and paragraphs 8.3.37- 8.3.38.
7.6.9 In terms of the impact on highways the application can therefore be considered to be compliant with The Isle of Man Strategic Plan 2016 Waste Policy 1, subject to the inclusion of conditions relating to the implementation of the mitigation proposals set out in the EIA Report, paragraphs 8.3.23 - 8.3.30 and paragraphs 8.3.37- 8.3.38 and Table 10.1 (Recommended Condition Nos. 1, 5 and 9).
7.7 Other Matters
7.7.1 One of the key aspects of the proposal is to ensure the stabilisation of the bund at the southern end of Field 314574 within which the deposited dredged material is contained. As set out above this forms a substantial embankment on the north side of the A20 Poortown Road. The pre-restoration works include bund stabilisation works, comprising the re-grading of the slope gradient of the bund's external face to approximately 1 in 2 and reducing the bund's crest height, installing geo-grid webbing and the seeding of the external face of the bund. The aim is to achieve an acceptably low long-term stability risk. Whilst detailed design work is still required the proposed works will seek to reduce any risk of ground instability in accordance with The Isle of Man Strategic Plan 2016 Environment Policy 28.
7.7.2 The areas of Fields 314574 and 314514 used for the silt store were used for agricultural grazing prior to the construction of the silt store in 2015. Field 314574 covers approximately 2 hectares and includes the silt store's bunded storage area in its lower part (approximately 0.5 hectares) and open agricultural land (grazing land) in its upper part (approximately 1.5 hectares).
7.7.3 Field 314514 covers approximately 1.7 hectares and includes the settlement pond in its lower part (approximately 0.1 hectares) and open agricultural land (grazing land) elsewhere (approximately 1.6 hectares).
7.7.4 Under the proposed development, the bunded storage area in field 314574 will remain in place indefinitely with restoration to a nature conservation end-use that will be undertaken by seeding and/or planting to restore habitat within the bunded storage area and to improve habitat in the dry woodland area fronting the bunded storage area and adjacent to Poortown Road. In addition, restoration works for nature conservation end-use will be undertaken by re- profiling the field area to the north of the bunded storage area and seeding to improve habitat. The leachate treatment area in field 314514 will remain in place temporarily until it is decommissioned and the land restored for agriculture grazing end-use.
7.7.5 As a result part of the restoration scheme allows for agricultural land, and part would result in a long term loss of agricultural land but an increase in habitat. This is not considered to be a reason for refusal.
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7.7.6 In relation to climate, the EIA considers the impact of the proposed development on climate due to greenhouse gas emissions, and concludes a negligible impact, noting the proposed restoration and monitoring activities.
7.7.7 It is noted that DEFA Minerals have raised no objection.
8.0 CONCLUSION
8.1 The retention of the existing deposited material on the site, is considered to be the best available option, for which there is a clear need and for which there is no immediately obvious and available alternative. As such it can be considered that the case is made that there is an acknowledged need, taking into account whether there are any potential alternatives in accordance with The Isle of Man Strategic Plan 2016 Waste Policy 1 and General Policy 3, insofar as there is an acknowledged need for the proposal in accordance with the approved Waste Management Strategy in providing void space for what is a problematic waste, and an overriding national need that justifies development outside allocations insofar as there is no reasonable and acceptable alternative. The main considerations then are whether the proposal is acceptable in terms of it environmental impacts.
8.2 In terms of the environmental impacts the proposal potentially causes a minor adverse impact on ecology largely due to the potential for pre-restoration and restoration works to destroy, damage and/or disturb the habitats and species associated with the species-rich ground flora, veteran trees and potential roost features for bats, and bird nesting areas at and around the silt store. The submitted EIA Report identifies these impacts as requiring mitigation. Impacts on habitats and species require mitigating through a series of measures including the use of steel plates (or equivalent) to protect ground flora and soil, restrictions on tree branch removal to protect PRFs for bats, advanced clearance of saplings and scrub to protect nesting birds, and limited excavations to protect tree roots.
8.3 The proposed development causes minor adverse impacts on traffic, noise and air quality along the local road network (i.e. the A20 Poortown Road) largely due to the truck movements associated with the delivery of construction materials and construction plant to the silt store. These impacts will be temporary but can be addressed through mitigation through the implementation of implementation of the construction traffic mitigation measures set out in the EIA Report. Successful implementation of the mitigation measures would result in negligible adverse residual impacts and, therefore, insignificant residual impacts on traffic, noise and air quality.
8.4 The proposed development's impacts on the water environment (i.e. surface water quality and groundwater quality), on landscape character and views, and on climate, are largely addressed by mitigation embedded within the proposed development, and do not require additional mitigation.
8.5 The application can accordingly be considered to be compliant with The Isle of Man Strategic Plan 2016, Strategic Policy 4, Waste Policy 1, General Policy 3, and Environment Policies, 1,2, 7, 22 and 28, and is therefore recommended for approval subject to the conditions set out the Conditions section at the beginning of this report.
9.0 INTERESTED PERSON STATUS
9.1 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);
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(b) any Government Department that has made written representations that the Department considers material; (c) the Highways Division of the DOI; (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.
9.2 The decision maker must determine:
o whether any other comments from Government Departments (other than the DOI Highway Services Division) are material; and o whether there are other persons to those listed above who should be given Interested Person Status
9.3 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.
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I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to that body 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 and/or rights to appeal.
Decision Made: Permitted Date: 26.01.2026
Signed : Mr Andrew Sierakowski Presenting Officer
Customer note
This copy of the officer report reflects the content of the office copy and has been produced in this form for the benefit of our online service/ customers and archive record.
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PLANNING COMMITTEE DECISION 26.01.2026
Application No. : 22/00287/B Applicant : Department Of Infrastructure Proposal : Restoration of existing silt store to create and maintain a permanent facility for storage and monitoring of dredged material from Peel Marina Site Address : Rockmount Silt Store Poortown Road Peel
Presenting Officer : Andrew Sierakowski
Addendum to the Officer’s Report
During the Planning Committee meeting, the Case Officer amended their recommendation in relation to condition 1 (timing changed to 18 months - as set out below) and the Committee approved the application with this amended condition.
C 1. Within 18 months of this decision becoming final, and prior to the commencement of any further works on site, a Detailed Design and Programme of Works as set in in paragraph 2.4.1 of the Environmental Impact Assessment Report ("the EIA Report") dated February 2022 prepared by Anthony D Bates Partnership which is informed by the ground investigation works set out at paragraphs 2.4.2 - 2.4.5 of the EIA Report shall be submitted to and approved in writing by the Department. The Detailed Design and Programme of Works shall set out a detailed design, consistent with the concept for the restoration scheme set out EIA Report Section 2.3 and paragraph 2.4.6, and include a programme for all of the pre-restoration and restoration works set out in the EIA, including:
o Pre-restoration works to trees on access track (paragraph 2.3.13); o Pre-restoration works to Field 314574 including bund stabilisation (paragraphs 2.3.15 - 2.3.18), engineered cap (paragraphs 2.3.19 - 2.3.22), surface water drainage (paragraphs 2.3.23 - 2.3.24) and monitoring wells (paragraphs 2.3.25 - 2.3.26); o Restoration works to Field 314574 including seeding of the external face of the bund and restoration layer of the cap (paragraphs 2.3.28 - 2.3.32), planting at the dry woodland area fronting the bunded storage area (paragraphs 2.3.33 - 2.3.42), re-profiling and seeding of the field area to the North of the bunded storage area (paragraphs 2.3.43 - 2.3.46); o Pre-Restoration Works to Field 314514 comprising the decommissioning of leachate management area (paragraphs 2.3.48 - 2.3.49); and o Restoration works to Field 314514 including a wet woodland planting area (paragraphs 2.3.51 - 2.3.60) and restoration of the remainder of the field to be suitable for grazing (paragraphs 2.3.61 - 2.3.63).
The development shall be carried out in accordance with the approved Detailed Design, including approved Programme of Works.
Reason: To ensure the submission for approval of a Detailed Design and Programme of Works, consistent with the concept for the restoration scheme set out EIA Report. __
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