DEC Glen Wyllin - Inspector's Report
Report to the Council of Ministers on a Planning Application
by Glen Wyllin Camping (2016) Limited for planning approval for the erection of 8 moveable camping pods, 7 cabins, barbecue area, bollard lighting, 2 canvas yurts, car parking area, drainage channels (part retrospective), extension to the facilities building and erection of 2 sheds; and extension of the camping period for the five cabins on the upper section until the end of December in any year, at Glen Wyllin Camp Site, Glen Wyllin, Kirk Michael, Isle of Man, IM6 1AL. _________________________________________________________
Introduction
- 1. I have the honour to report that, on 11 December 2023, I carried out a site inspection at the above location. The case is being made by written representations.
- 2. The application has to be considered by the Council of Ministers, not the Planning Authority, because it is for development on land which is owned by the Department.
Procedural Matters
- 3. The application is part retrospective and the written representations and Departmental advice make reference to a previous unsuccessful application, Ref 17/00386/B, for camping facilities at the application site. These matters notwithstanding, the present proposals fall for fresh and independent consideration on their own planning merits and the partial retrospective status of the proposals makes no difference to the assessment of the planning issues that arise.
Site Description and the Proposals
- 4. The application site is an irregularly shaped parcel of land comprising a variety of separate camping areas within the Glen Wyllin Camp Site. The land is leased by the Applicants.
- 5. The Camp Site is between Glen Wyllin beach to the north west and the A4 coastal highway to the south east, with the Broogh Wyllin and Cleiy Rhennee housing areas in southern Kirk Michael on higher ground to the north east.
- 6. The site encompasses the deep National Glen of Glen Wyllin with its significant tree cover and central stream, traversed by several bridges, and accommodates seasonal tent and caravan camping facilities. An access track passes through the site to the beach and its associated parking area.
- In the centre of the site there is a children’s play area and a group of buildings providing facilities for campers and Glen visitors.
- 7. The site is within the designated Glen Wyllin Conservation Area (CA).
- 8. The Camp Site is currently conditioned to operate only from 1 April to 30 September.
- 9. The proposed development would comprise:
- a. The installation of 8 mobile camping pods, partially surrounded by a shallow flood bund of maximum height 0.4m, on a grass area northwest of the facilities building and just south of the stream. The pods would be 3.6m by 2.4m by 2.6m high overall, with a front deck of 1.2m by 2.4m, constructed in timber and finished in larch boarding under a shallow hipped roof in lightweight tiles;
- b. The erection of 5 single-storey cabins on an upper area north of the stream, alongside the residential property of Glenside, together with a barbecue unit. The cabins would be some 7.4m by 4.6m by 3.7m high overall, including a covered front deck of 1.8m by 4.6m, also constructed in timber and finished in larch boarding under a pitched roof in lightweight tiles.
- c. The erection of 2 further similar cabins just east of the caravan and motorhome camping area in the eastern part of the site.
- d. The installation of 2 canvas-roofed, 5.5m diameter yurts to the north of the motorhome camping area. These would be 3m high overall with 1.7m timber side walls.
- e. The installation of bollard lighting leading up to the above 5 cabins from the access track.
- f. The creation of a car parking area to the south west of the access at the southern end of the site.
- g. The installation of ground drainage, already completed, to assist water flow from the camping area; and
- h. Alterations and a 1.9m deep rear extension along the 11.4m length of the single-storey, main facilities building, to provide additional storage space, together with 2 additional sheds to the south east of the main building.
- 10. The new development would result in the removal of 10 of the existing 70 caravan pitches and some 33 of the existing tent pitches. 80 tent pitches south west of the road would remain, with dedicated parking.
- 11. Further approval is sought to extend the camping period for the five cabins on the upper section from September until the end of December in any year.
- 12. The application was accompanied by a Flood Contingency Plan, Preliminary Ecological Appraisal (PEA) by Manx Wildlife Trust with a report from Manx Bat Group, and a Transport Statement1
Planning History
- 13. The Glen Wyllin Camp Site has a long and complex planning history having, evolved over many years 2. However, it is not disputed that the use of the land for camping is well established.
- 14. Of most significance to the present appeal is the refusal by the Council of Ministers of a previous application under Ref 17/00386/B, for 46 caravan pitches and 120 tent pitches, 2 yurts and 8 two-storey camping pods, for reasons including adverse impact on the open character of the Glen Wyllin CA and the lack of an Environmental Impact Assessment (EIA).
- 15. Since 2017, further planning history has come to light, indicating the grant of permission long ago for the use of the whole of the site for camping throughout the season and not only for the TT and MGP periods.
Planning Policy and Guidance
- 16. In the Kirk Michael Local Plan of 1994, the application land is zoned as open space, with a recommendation that the use of the site as a tourist facility be maintained and developed to expand its offer as a local amenity asset. This position is consistent with Tourism Policy 4 of the Draft Area Plan for the North and West and Business Policy 11 of the Isle of Man Strategic Plan 2016 (IMSP).
- 17. Strategic Policy 5 (StrP5), General Policy 2 (GP2) and Environment Policy 35 (EP35) of the IMSP are relevant with respect to the general control of development and the preservation or enhancement of the character or appearance of the Glen Wyllin CA.
- 18. Environment Policy 1 (EP1) protects the countryside and EP3 protects trees. EP10 and EP13 deal with flood risk, requiring an appropriate flood risk assessment in connection with any application and resisting development that would be at undue risk of flooding. Transport Policies 4 and 7 (TP4-7) safeguard road safety and set parking standards.
- 19. Environment Policy 24 (EP24) and Appendix 5 of the IMSP set out requirements for EIA, including for new camp sites.
- 1 Application Details online
- 2 Department Advice Note Section 4
- 20. The IMSP at Chapter 9 makes clear that tourism developments are subject to the same constraints as other forms of development whilst, in Chapter 10, the benefits of recreation are acknowledged and Recreation Policy 2 (RP2) specifically protects open space.
- 21. The Manx Visitor Economy Strategy of 2022 is relevant in promoting an improved tourism offer.
Statement by the Applicants
Full details of the proposed development are provided in an illustrated Application Statement3 and statement of Case4 on behalf of the Applicant company.
The material points are: Introduction
- 22. The Applicants are about to start season 7 of a 21-year lease and wish to invest in the facilities at the site for the benefit of the remainder of their tenure and potentially to extend it further in the future.
- 23. They also wish to extend the period in which some of the camping activity can take place on the site. Currently the Camp Site is open from 1 April to
- 30 September and it is proposed to open for an additional period, limited to the 5 proposed cabins on the upper section of the site, to be available until
- 31 December in any year.
- 24. The present proposal addresses the reasons for refusal of the previous 2017 application. The development now proposed would enhance the visitor experience at the Camp Site, extend the range of accommodation and increase the length of time visitors may remain on the Site. It would also manage flood risk and regularise the use of the land as a camp site.
- 25. As the site is owned by the Department, it may at any time control how the site is used and vary or even terminate the lease to the Applicants.
Land Use
- 26. It is evident and undisputed that the use of the site as a camp site has been established for a considerable time, as noted by the Inspector in connection with the 2017 application. This use is likely to continue, irrespective of whether this application is approved.
- 27. Given the historic use as a camp site with children’s play facilities and a public highway giving access to the National Glen and the beach, it is considered that the development now proposed would not be harmful to the
- 3 Application Details – Planning Statement
- 4 Statements of Case – Statement on behalf of the Applicant
function of the area as available public open space, even though some parts of it are not be accessible to the public.
Environmental Impact Residential Amenity
- 28. The previous Inspector did not consider this to be an issue.
- 29. The development is a significant distance from most existing dwellings in the area. Almost all are set higher than the application site. It is not considered that the development now proposed would have any adverse impact on properties in Broogh Wyllin or Cleiy Rhennee.
- 30. The proposed cabins would sit relatively close to Glenside but the nearest cabin has been designed with no windows facing that property and there is a solid wall between the neighbouring residential curtilage and the location of the proposed cabins, the nearest of which would be closer to the garage than the living accommodation.
Biodiversity
- 31. The grassland affected is closely mowed for amenity use and therefore of little ecological interest.
- 32. The PEA notes plentiful birds on and around the site but no scarce plants or protected species apart from three recorded species of bat in the vicinity, the site itself being used for foraging.
- 33. The PEA concludes that the development would mainly involve changes to the use of the amenity grassland of low ecological value and, as the site is used for camping, there is unlikely to be any additional disturbance to surrounding woodland and scrub areas.
- 34. The main concern relates to impact on wet ditches and the stream, although it is not known whether the ditches are used by breeding common frog or whether the proposed changes to the drainage would have an impact on water levels. It is noted that the area as a whole is subject to flood risk with varying river flow rates.
- 35. The PEA recommends the installation of bird and bat boxes and specifically refers to house martin and house sparrow, although nest sites for these are not thought to be within the site.
- 36. The Applicants do not believe that the development would have any adverse effect on ecology but are happy to enhance the biodiversity value of the site by introducing bird and bat boxes on the proposed buildings or trees, as advised by the Department and secured by condition.
Climate Change
- 37. With reference to the Visitor Economic Strategy, the provision of additional facilities at this site would increase the range of on-Island recreation and tourist facilities for Island residents as well as for off-Island visitors. This would provide a more sustainable holiday experience for residents than travelling off-Island, as well as supporting access to the natural recreation facilities of the adjacent coast and footpaths. This would be in accordance with Chapter 10 of the IMSP which acknowledges the benefits of recreation and open space.
Public Access, Cultural Heritage and Trees Public Access
- 38. There is some third-party concern over the prevention of access by the public to parts of the site. The public would still have access to the children’s play facilities, the Glen on the south western side of the road, and the beach whereas, ever since the Camp Site has been operational, the public have generally not had access to the land north east of the road. The previous Inspector noted that there are no known plans to make the area functional public open space.
Cultural Heritage
- 39. Cultural heritage is addressed because the site lies within the Glen Wyllin CA.
- 40. The previous Inspector noted that tents, caravans and motorhomes and other paraphernalia may detract from the open, unspoilt appearance of the CA and National Glen but that this would continue in any event, such that the camping development would have only a marginal effect and would allow for more control over the number and location of tents and caravans. The Registered Building Officer (RBO) had also considered the impact negligible.
- 41. The design of the cabins and pods has now been changed to an exclusively single-storey form, more akin to what may be expected on a camp site, and have been specifically designed for the site. The cabins and pods would be rectangular, like the facilities building and dwellings in the vicinity. This would result in a positive change to the CA, compared with the tents and caravans currently in the same position, noting that, importantly, the CA Appraisal itself acknowledged the presence of the Camp Site.
- 42. The Glen Wyllin CA is unusual in containing few buildings, whereas the focus of designation would normally be on special or historic interest of buildings and neighbourhoods. This CA was clearly not designated for its architectural quality. The Appraisal refers to the Camp Site as having two buildings, with the cafe building harmonising in its surroundings but the ablution block described as ugly. The Appraisal also notes visual intrusion from nearby residential development. The history of the CA is
- predominantly as a public Glen providing access to the beach and it will continue to do so. Lively summer activity is not considered detrimental.
- 43. These proposed developments, appropriately designed for their location, would not significantly change the appearance of the Camp Site. The main areas for motorhomes and tents would remain as existing and the location of the proposed cabins would be largely screened by trees from the principal views along the public highway.
Trees
- 44. There are potential concerns over engineering and drainage operations affecting trees. Since the previous application, trial holes have been opened to prove that no tree roots would be affected. 100mm pipes have been laid in channels 400mm deep or in existing channels to discharge into the river. This keeps the camping areas drier and has no effect on existing trees.
Access, Highway Safety and Parking
- 45. There is no objection to the present proposal by DOI Highway Services. The submitted drawings show details of parking and visibility available at the Camp Site entrance. It is not considered that the proposed development would significantly alter the traffic movements and parking requirement over and above those currently generated by the Camp Site. This is confirmed by the submitted Transport Assessment.
Vulnerability to Flooding and Landslip
- 46. Parts of the site lie within areas of high risk of surface water flooding, according to the Flood Risk Assessment. The DEFA Flood Risk Management Team identify only the area of the 8 pods as lying below estimated flood levels. The proposed 0.4m high flood bund addresses this.
- 47. The FRA also identifies the need for a Flood Evacuation Plan specific to the Camp Site to be secured by condition.
- 48. The 2017 application also identified a potential risk of landslip but a civil engineering consultant report stated that, despite a previous landslip, the area was now considered to be stable and that there was no reason why camping could not continue on the site, provided that there were no changes in the condition of the slope concerned. The Department has confirmed that there has been no further slippage and that they continue to inspect the area at the start of each season.
Conclusion
- 49. The previous 2017 application is a significant starting point in assessing the present proposal, which is very similar in many respects.
- 50. The previous Inspector noted that, in the Kirk Michael Local Plan, the site is within an area allocated as public open space but that its use is not
- consistent with that designation, so that GP2 of the IMSP, which relates to development that accords with land-use zoning in the Area Plan, did not apply. However, there is no known proposal for this land to be used as public open space, and camping is the established use, which was likely to continue, whether or not the planning approval sought was granted. On balance, the inconsistency between the proposed use and the Local Plan zoning did not tell against the application.
- 51. Nor was it found that the proposed development would affect the privacy of neighbouring residents north of the Glen; weight was attached to the conclusions of the civil engineering consultant that the slope where there was previously a landslip can now be considered stable, subject to annual inspection; the proposed development should not affect any public right of access; and the camping use clearly makes a welcome contribution to the Island tourism offer, potentially widened by a time extension. The previous Inspector concluded that the advantages of the camping use would strongly outweigh the disadvantages.
- 52. However, the factors that led to the refusal in that case were the perceived adverse impact on the CA through detraction from openness and visual amenity that would neither preserve nor enhance its character or appearance, as well as the lack of an EIA or FRA.
- 53. For the present Applicants, it is now submitted that those issues have been satisfactorily addressed and that the current proposed development would not have an adverse impact on the Glen Wyllin CA, in terms of relevant policy.
- 54. Since the previous application, the Government has published its strategy for the development of tourism on the Island and this aims to increase visitor numbers, making the most of the key unique selling points of the Island, namely its coastline, the sea, the countryside, and its heritage.
- 55. The development would reduce the overall number of camping units on the site and significantly improve the quality and visual impact of the Camp Site, enhancing car parking provision, mitigating flood risk and addressing areas of the site which were prone to water-logging, so making better use of it and retaining the tourism use.
- 56. The development would enhance the attractiveness of the beach and coastline through presentation of a better-looking camp site as visitors pass through to the beach and Raad ny Foillan coast path. It is suggested that the present proposal is in accordance with, and would help achieve Government aims in its recently published strategy.
- 57. The development would reduce the impact of the Camp Site on the closest houses by the provision of better car parking and replacing tents with a smaller number of solid-walled units, the nearest to Glenside having no facing windows.
- 58. It is submitted that the current application addresses all of the previous reasons for refusal and complies with all of the relevant planning policies.
Conditions
- 59. The Applicants would accept conditions restricting the operating times of the site to 1st April to 30th September in any year but with the 5 cabins adjacent to Glenside being available between 1st April and 31st December in any year, in accordance with the application.
- 60. A condition may be appropriate to require details to be approved prior to the erection of any of the proposed buildings for the location and type of bird and bat boxes, preferably on existing trees which may be more suitable than the proposed low-level cabins.
- 61. A further condition may be necessary to secure the Flood Evacuation Plan. Representations Received Representations received are recorded online in full5. The material points are:
- 62. Michael Commissioners have no objection.
- 63. DOI Highways Services note no significant negative impact upon highway safety, network functionality or parking.
- 64. DOI Flood Risk Management have no objection subject to conditions that the flood bund must be constructed as proposed and that the Flood Contingency Plan is implemented.
- 65. The DEFA Ecosystems Policy Officer confirms that the Manx Wildlife Trust PEA is in order and that a suitable level of assessment has been undertaken but approval should be subject to a condition to secure mitigation measures detailed in that Appraisal.
- 66. The DEFA Registered Buildings Officer has no objection, commenting that the development would have a neutral impact on the character of the Glen Wyllin CA, which is divided into two distinct areas. The area of this application is the western portion of the CA, long recognised as a pleasure resort and tourist destination. The proposed use of single-storey buildings with natural timber wall finishes is welcomed.
- 67. DEFA Fisheries have no objection
- 68. DEFA Forestry note that the development would significantly reduce the chance of harm occurring to trees, subject to conditions to secure drainage and root protection as proposed.
- 5 Representations – all documents
- 69. Manx Utilities Authority has no comments, save that any connections to the public drainage system should be approved in advance.
- 70. Visit Isle of Man recognise Glen Wyllin Camp Site as a long-established, registered, three-star camp site, operating from April to September, offering some 190 varied tent and caravan pitches, some with electrical hook-ups. The proposals are consistent with the Visitor Accommodation Transformation Programme of the Our Island, Our Future Visitor Economy Strategy 2022-2032 in terms of achieving a higher quality non-serviced accommodation offer that will help to boost off-peak demand and attract new visitor markets to the Island.
- 71. Two letters from local residents raise additional relevant concerns summarised as follows:
- a. The proposed development would lead to loss of public amenity;
- b. It is not clear where the 8 mobile camping pods might otherwise be sited in the future;
- c. Permanent cabins and barbecue facilities mean less public open space and public amenity for Glen users, regardless of actual occupation;
- d. The 2 yurts and further 2 cabins on the north side of the upper Glen would lead in effect to a restriction on a previously enjoyed winter access;
- e. The proposed structures would be highly visible from all directions once leaves have fallen, unless sympathetic roof and wall colourings are used;
Advice from the DEFA Planning and Building Control Directorate Detailed advice on the application is provided by the Department without recommendation 6. The material points are: Planning Issues
- 72. The main issues in this planning application are:
- a. Principle of development
- b. Design and visual impact - Conservation Area and wider landscape
- c. Residential amenity impact
- d. Environmental impact
- e. Highways impacts and parking
Principle
- 73. The application site comprises an established tourist facility which has been in continuous operation since at least the adoption of the Kirk Michael Local
- 6 Statements of Case – Advice from the Department
Plan in 1994. The land is zoned as open space but with a recommendation that the site be developed and improved as a tourist facility.
- 74. The Inspector who assessed the previous scheme noted that the present use has become immune from enforcement action and was likely to continue, irrespective of the outcome of that application. That Inspector considered that the potential land use conflict should not weigh against the previous application.
- 75. Since then, further planning history has come to light, indicating the grant of permission long ago for the use of the whole of the site for camping throughout the season and not only for the TT and MGP periods.
- 76. Accordingly, the proposed development to enhance the visitor offer of the Camp Site, is acceptable in principle.
Design and visual impact on the Conservation Area and landscape
- 77. In response to the previous Inspector's assessment of the earlier scheme, the Applicants have set out (above) how the present scheme seeks to overcome prior objections in its design and layout, supported by certain environmental information.
- 78. The RBO notes that the site was long used as a camp site, since before the designation of the surrounding CA, and concludes that its continued use as such would preserve the special character of the CA, welcoming its use of natural timber for exterior finishes.
- 79. In light of the above comments, it is the view of officers that the proposals would not result in a detrimental impact upon the special character and appearance of the CA.
- 80. Whilst it is appreciated that the proposals would introduce additional permanent development within the site, such proposals would reduce the number of tent and caravan pitches currently available.
- 81. The character and appearance of the site for much of the year is that of an established camp ground, which includes an eclectic range of tents, caravans and motorhomes. Therefore, the development of modest structures as proposed would, in the opinion of officers, do little to add to the intensification of use or activity on the land, whilst introducing a small number of well-designed structures that would sit comfortably within the site.
- 82. Likewise, such development would not be readily apparent from key views outside the Camp Site and, indeed, would only be visible within the context of the Site itself. The inclusion of such structures, as further noted by the RBO, is not uncommon within established camp sites.
- 83. No concerns are raised from a design perspective over the modest rear extension to the existing shop building or to the proposed erection of 2 sheds immediately to its east.
- 84. Consequently, it is considered that the proposed development is acceptable from a design and visual impact perspective, with the changes to the proposed operational development deemed sufficient to have successfully overcome previous concerns and objections held by the Inspector in relation to the previously refused scheme.
- 85. In this respect, the proposals are therefore considered to be in conformity with the relevant provisions of StrP5, GP2 and EP35 of the IMSP, in particular with respect to the Glen Wyllin CA.
Residential Amenity
- 86. The land has been in continuous use as a camp site for a significant period, with the only element likely to have any material impact comprising the 5 cabins proposed on a plateau within the proximity of the residential property of Glenside at the base of Gorse Bank, together with properties at the top of the Bank, within Shore Road and Cleiy Rhennee.
- 87. The current proposals are broadly similar to those previously considered in the 2017 application when, due largely to the established status of the camping use, the proposal was not considered significantly detrimental to the amenity of surrounding residential properties. Indeed, the plateau area, where the 5 cabins and barbecue area would stand, is already frequently occupied by tents during much of the year. Whilst the proposals would introduce permanent structures to this location, the use and occupancy of such cabins would be largely equivalent to the current situation. Therefore, any noise or activity associated with the cabins would be comparable.
Environmental Impact
- 88. The previous application was in part refused for the lack of an EIA to cover matters including flood risk, drainage and arboricultural issues.
- 89. The submission of an EIA is required by EP24 of the IMSP for the development of new permanent camp sites on the Island. The current application is accompanied by some environmental information, albeit not as robust as might typically be expected.
- 90. Nevertheless, the Department considers the environmental information submitted to be sufficient for the assessment of the application with respect to all relevant planning matters identified by the scoping exercise, particularly in relation to impact on the Glen Wyllin CA, drainage, flooding, arboriculture and biodiversity.
- 91. As the use of the land as a camp site has been established as lawful, the currently proposed development would not amount to the creation of a new
- permanent camp site and the submission of an EIA is not required in any event.
- 92. Submitted technical advice and photographs by Manx Roots provides an overview of potential arboricultural impacts as a result of the proposed drainage and corresponding mitigation measures. This information is considered by the Department Tree Officer to be acceptable, subject to the conditions listed in the consultation response.
- 93. Consequently, the reason for refusal of the 2017 application due to a lack of environmental information is now considered to have been successfully overcome.
Flood Risk
- 94. No concerns have been raised by the DOI Flood Risk Management Division based upon a submitted Flood Risk Assessment (FRA), Flood Evacuation Plan and details of a proposed flood bund around the lower camping field. That is subject to conditions to secure the construction of the bund and implementation of the Contingency Plan. The level of information submitted in this respect is also considered to be acceptable, overcoming the corresponding previous reason for refusal.
Highways Impacts and Parking
- 95. No concerns are raised by DOI Highway Services. The application site is already in operation as a lawful camp site, with the proposed operational development unlikely to result in a material uplift in traffic associated with the established operation of the site. That is given the proposed alterations would result in a reduction of 40 tent pitches and 10 caravan hook-up points, balanced against the introduction of the 8 camping pods, 7 log cabins and 2 yurts.
Conclusion
- 96. The application relates to DEFA-owned land and the Department would benefit from the application being approved. This report sets out the key issues and considerations, some potentially addressed by planning conditions, but no overall recommendation is made as to whether planning approval should be given.
- 97. A full set of potential draft conditions is provided.
Assessment by the Inspector
Principle of Development, Scope of the Application and Planning Issues
- 98. The written representations rely strongly on a comparison of the present application with the previously unsuccessful scheme of 2017.
- 99. Such comparison is material but ultimately this application is for determination on its own individual merits under current planning circumstances and policy.
- 100. There are significant differences between the present and previous schemes. The 2017 proposal was described as being for a new camp site of some 46 caravan or motorhome pitches and 120 tent pitches, 8 cabins, 8 pods and 2 yurts, operating from February to November. As a new camp site, the application should have been accompanied by an EIA and the Inspector found against the proposals for lack of environmental information, as well as a measure of adverse impact, failing to preserve the appearance or character of the Glen Wyllin CA and overriding any benefits.
- 101. This present application and the circumstances surrounding it are markedly different.
- 102. First, the planning history of the application land now clearly shows that its long-term established use is as a campsite, despite its status in the Kirk Michael Local Plan as open space, albeit with acknowledged tourist use. The previous Inspector came to the conclusion that any inconsistency in designation did not tell against the earlier proposal.
- 103. Since then, it has become even clearer that the present camping operation of some 70 caravan and 120 tent pitches from April to September is immune from enforcement and likely to continue into the future, with or without the developments for which approval is sought in this present application.
- 104. Second, the current proposal is for a limited number of alterations and additions to the Camp Site facilities, within the area of established camping use and operating over the same time period from April to September, save only for the 5 cabins proposed north of the river adjacent to the residential property of Glenside.
- 105. It follows that there can be no objection in principle to camping developments within the application site.
- 106. Taking account of the reduced scope of the present application, all the written representations, the conclusions of the previous Inspector and the current planning history and circumstances of the application site, I consider that the main issues for consideration in this case are the effects of the proposed developments on the appearance and character of the surrounding Glen Wyllin CA and on residential amenity.
- 107. It is also necessary to consider other matters of flood risk and drainage, ground stability, biodiversity and trees, parking and highway safety, as well as planning benefits.
Appearance and Character – Glen Wyllin CA
- 108. The Glen Wyllin CA is unusual in that it is essentially rural and its special character is derived not from the architecture of a built environment but from its openness, attractive landscape and relationship with the sea, as part of Island cultural heritage.
- 109. The requisite policy test is whether the net effect of this range of built developments may be judged overall to preserve or enhance the character or appearance of the CA. That depends, in this case, on their scale, form and finishes, as well as the degree to which they would reduce the openness or rural nature of the landscape and public access to it.
- 110. The previous Inspector found that the proprietary, two-storey, permanent cabins proposed in that case would appear in the context of a larger-scale camping proposal, as conventional dwellings of a kind not to be expected on a camp site. He accordingly found that they would fail to preserve the openness, character or appearance of the rural CA.
- 111. In the present case, the 7 cabins are of a single storey, in rustic timber finishes and, to my own mind, a little reminiscent of traditional beach huts. The 8 mobile pods are similarly discrete in their form and design, being also significantly smaller than the cabins. Although mobile, any future re-siting would require further approval.
- 112. The extension to the facilities building and the 2 accompanying sheds would be of modest proportion and would be integrated into the existing built group. The additional bollard lighting would not be objectionable in the context of the surrounding Camp Site.
- 113. Naturally, there would be a noticeable reduction in openness, especially in winter when the campsite would be largely closed and trees would be bare. In the camping season though, the proposed structures would displace a substantial proportion of the eclectic selection of tents to be found on any camp site.
- 114. Public access and enjoyment of the Glen, children’s playground and the beach would not be altered, given there has historically been little or no public access north of the River.
- 115. Despite the cabins and pods on the south side being always visible from within the Glen, I agree with the RBO that the impact upon the CA would be neutral overall and that the development would thus preserve its the character and appearance, in accordance with EP35 of the IMSP. Also, it would not significantly undermine the aim of RP2 of the IMSP to protect public open space.
- 116. I consider that the pods, cabins and other proposed facilities would be barely noticeable in more distant views from outside the Glen. It follows that the protection to the wider countryside landscape afforded by EP1 would also be met.
Residential Amenity
- 117. The chief concern is evidently the proximity of the proposed 5 cabins, on the upper level of the site north of the river, to existing residential property there, in particular Glenside. However, the omission of any facing windows in the closest cabin would avoid overlooking and the buildings would be separated by the intervening boundary wall and vegetation. The area to be occupied by the cabins is already largely occupied by tents in the season, some of which the cabins would displace.
- 118. Therefore, whilst there will always be a degree of noise and disturbance to neighbours from the camping area, on the whole I do not consider that it would increase as a result of the presence of the cabins.
- 119. Further, I take the view that the proposed increase in the period of occupation of the 5 upper cabins from September to December would cause no significant harm to amenity. A condition is necessary to impose that time limit.
- 120. I have seen no evidence of any unduly adverse impact on the amenity of any other property, noting that the houses in the southern parts of Kirk Michael are significantly separated from the application site by a tall bank at the side of the Glen.
- 121. Accordingly, I find that, to the extent that its provisions apply, the development meets GP2 of the IMSP regarding the protection of residential amenity.
Other Matters Flood risk and drainage
- 122. On the evidence available and summarised above, flood risk has been properly assessed in connection with this application, resulting in a modest flood bund being proposed around part of the site of the 8 mobile pods, with no other measures required apart from a Flood Evacuation Plan, both to be secured by planning condition.
- 123. The field drainage has already been installed, evidently without damage to trees, as one feared, according to investigations reported by the Applicants and unchallenged.
- 124. In these respects, the proposed development may be judged compliant with EP3, EP10 and EP13 of the IMSP, subject only to advance approval of any drainage connection as required by Manx Utilities.
Ground stability
- 125. Despite a former landslip above the site of the proposed 5 cabins, there is no evidence of any repetition of that danger and expert opinion is that the site is safe in this regard.
Ecology and trees
- 126. The submitted PEA is unchallenged and raises no significant ecological concerns due to the proposed development, only suggesting certain precautionary mitigation measures related to trees and lighting and the inclusion of bat and bird boxes to support species known or likely to be present. These can be secured by condition.
- 127. There is no evident danger to trees now that the drainage work is complete, as noted above.
Parking and highway safety
- 128. There is no evidence that there would be any net increase in traffic to and from the application site due to the proposed alterations, given the corresponding reduction in the number of caravan and tent pitches. It follows that there would equally be no increase in parking demand but an improvement to the parking arrangements by the conversion of the southern camping area to accommodate parked cars close to the site entrance.
- 129. There is accordingly no objection from the highway authority and the application is to be regarded as complaint with TP4 and TP7 of the IMSP with respect to highway safety and parking.
Planning benefits
- 130. The proposed development would upgrade the tourism offer of the Camp Site, representing a substantive planning benefit to the Island in accordance with its Visitor Economy Strategy.
Overall Conclusion
- 131. I have found no planning objections to the development proposed in this application. I therefore consider that it should be approved.
- 132. The measurable benefit to tourism weighs further in support of this conclusion.
Recommendation
- 133. I recommend that planning approval be granted for the erection of 8 moveable camping pods, 7 cabins, barbecue area, bollard lighting, 2 canvas yurts, car parking area, drainage channels (part retrospective), extension to the facilities building and erection of 2 sheds; and extension of the
camping period for the 5 cabins on the upper section until the end of December in any year, at Glen Wyllin Camp Site, Glen Wyllin, Kirk Michael, Isle of Man, IM6 1AL, in accordance with application Ref 22/00789/B, and subject to conditions set out in the Schedule appended to this Report for the reasons there stated. The suggested reason for approval and list of approved drawings are also appended.
B J Sims
Brian J Sims BSc (Hons) CEng MICE MRTPI Independent Inspector
14 December 2023
APPENDIX Schedule of Recommended Planning Conditions Reason for Approval List of Approved Drawings
C1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
C2. At no time shall the numbers of camping units on the site exceed a total of: 60 caravans or motorhomes, 120 tent pitches, 2 yurts, 8 log cabins, and 8 camping pods.
Reason: To ensure that the development takes place in accordance with the application and approved plans.
C3. No person shall be permitted to stay overnight on the site outside the months of April to September inclusive, exception for the 5 No cabins located in the northern portion of the site and associated barbecue area, where overnight stays may be permitted between the months of April and December inclusive.
Reason: To ensure that the development takes place in accordance with the application and in the interests of visual and residential amenity.
C4. No touring caravans shall be stored on the site outside of the months of April to September inclusive, and no static caravans shall be brought onto the site at any time.
Reason: To ensure that the development takes place in accordance with the approved plans and that the site is not used as permanent accommodation, in the interest of local amenity and minimising flood risk.
C5. Prior to the occupation of development, the flood bund shall be constructed in full accordance with the approved details and thereafter retained and maintained in perpetuity.
Reason: In the interests of safeguarding the site from flooding.
C6. The approved Wet Weather and Flood Contingency Plan dated April 2022 shall be implemented in full and in perpetuity.
Reason: In the interests of visitor safety.
C7. The mitigation measures outlined within section 6.1 of the Preliminary Ecological Appraisal dated November 2021, shall be carried out in full accordance with such details.
Reason: In the interests of safeguarding biodiversity.
C8. All external lighting within the site shall be erected in accordance with the approved drawings and shall comprise only downward pointing bollard lighting as specified within section 6.1 of the submitted Preliminary Ecological Appraisal dated November 2021. Further details must be submitted to the Department for approval in the event that a different lighting type is to be used or additional lighting is to be introduced to the site.
Reason: In the interests of safeguarding biodiversity.
C9. The approved development shall be constructed in full accordance with the recommendations and mitigation measures identified within the Arboricultural Advice document by Manx Roots, dated 6th February 2023, and the accompanying Referenced Photos document. Any deviation from the identified recommendations and mitigation measures must be submitted to the Department for approval in writing.
Reason: To safeguard the health and vitality of retained trees within the site.
- C10. The cabins, yurts and camping pods hereby approved shall not be used or occupied other than for the purpose of short-term holiday let accommodation and shall not be used as separate dwellings. They shall not be occupied by the same person or persons for a single period or cumulative periods exceeding 28 days in any calendar year.
Reason: The application has been approved on the basis of providing tourist accommodation only with any deviation in use requiring further assessment against adopted planning policy.
- C11. In the event that the use of the development hereby approved ceases for a period exceeding 36 months, the areas occupied by the development hereby approved shall be restored within a period not exceeding 30 months from the date of the cessation, in accordance with details which have first been approved in writing by the Department and which shall include the removal of the 8 camping pods, 7 log cabins and 2 yurts.
Reason: To ensure that the site is restored in the event that the use of the development hereby approved ceases, in order to protect the landscape of the Glen Wyllin Conservation Area.
- C12. Before the accommodation units hereby approved are first occupied bird and bat boxes shall be installed on the site in accordance with details which have been approved by the Department. Reason: In the interests of biodiversity.
- C13. Any connections to the public drainage system shall be made in accordance with details approved in advance by the Department. Reason: To ensure proper drainage of the site. Reason for Approval
The camping use of the site is established and the several components of the development would together have no net harmful impact upon the appearance or character of the Glen Wyllin Conservation Area nor upon the amenity of neighbouring residential property and would also avoid flood risk or harm to ecology or trees and would benefit Manx tourism. The development would thus comply with all relevant policies of the Isle of Man Strategic Plan 2016, in particular Environment Policy 35.
Approved Drawings and Information Received 27.07.22
- 103 - type A cabins
- 104 - type B cabins
- 105 - camping pods
- 106 - proposed BBQ area
- 109 - proposed shop alterations
- 110 - proposed yurts
- 111 - type C cabins
- 112 - visibility splays
- 113 - proposed sheds Flood depth document Flood Risk Assessment Manx Bat Group technical note Planning Statement Transport Statement Preliminary Ecological Appraisal
Received 15.09.22 Flood bunds details
Received 03.03.23
- 101 RevA - revised location plan
- 102 RevD - revised site plan
- 107 RevD - marked up areas in detail
- 108 RevC - area of uses plan Arboricultural Advice document and reference photos Deed map