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Variation of conditions 2 and 3 of PA 14/00689/C to extend the use of land at the former Ballakinnish Nurseries Site as a DOI Highways Depot for a further five years
Planning Statement of Case
Date: January 2025
On 13th January 2015 planning permission 14/00689/C was granted for the ‘Change of use of site from a former market garden to use for the storage of construction materials (retrospective)’ these materials arising from the then current projects in Douglas, namely;
The approval from DoI to replace the Secondary Waste Incinerator (SWI) has been submitted to SUEZ. It is expected the build and installation will be completed by mid-2026. The replacement of the current SWI is required due to extensive refractory damage which at any time could totally collapse and leave the Island without a facility to dispose of clinical waste from hospitals, GPs surgeries etc.
During build and installation phase sufficient clinical waste should be stored to ensure there is a sufficient quantity of clinical waste to commission the new SWI. Currently the SWI is only operated every 6 months, this has been done to prolong its operational life while treasury approval of £3,000,000 was obtained to purchase a replacement. During this time the bagged clinical waste has been incinerated in the Primary Waste Incinerator (PWI) and the clinical sharps waste stored in six to eight 20ft shipping containers stored at the Animal Waste Processing Plant (AWPP).
For the commissioning of the SWI, the quantity of clinical waste collected over 6 month is not sufficient, the commissioning of the new SWI will require at least twenty 20ft shipping containers filled with clinical sharps waste. There is not sufficient storage space at either the AWPP the Energy
from Waste (EfW) facility for twenty 20ft shipping containers. An alternative nearby storage site has been identified as Ballakinnish as this site is secure, located near to the Energy from Waste Facility, controlled by DoI and has CCTV. It is proposed that storage of the 20ft shipping containers will first be the AWPP, the EfW and the additional storage at Ballakinnish to be utilised for up to twenty 20ft shipping containers.
A copy of the decision notice and the Inspector’s Report for PA 14/00689/C are included in Appendix
This Planning Statement:
The A5 is designated as a primary distribution route providing direct access to Ronaldsway Airport as well as the south of the island. The route carries approximately 16,500 vehicles per day and along this section of the road, there is a 50 mph speed limit in operation.
In 1971 Ballakinnish started operating as a nursery, growing and selling cut flowers. Initially the business operated from 2000m2 of growing area under glass; gradual expansion over the following years took place such that in 1985, the growing area had increased to 15,500m2.
Picture1: Ballakinnish operating as a nursery
The site is mainly bounded by mature hedges and trees, with the A5 forming the southern boundary. Beyond the boundaries are agricultural fields. Amongst the fields are 4 properties, indentified in picture 2.
| Ballakinnish House |
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| Ballakinnish |
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| Croyton |
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| Brookside |
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Picture 2: Ballakinnish Nursery Site (18 acres) sold to Isle of Man Government and surrounding properties.
Other notable features close to the site are as follows (identified in Picture 3):
The previous occupier left the site in 2008 after selling it to the Isle of Man Government. In 2010 the then Department of Transport utilised the area as a site compound during construction of the Richmond Hill Highway Improvement scheme.
During this period, the site housed a welfare cabin along with construction materials and excavated arising’s required for the construction of the highway scheme.
Following completion of the Richmond Hill Highway scheme, the Department of Infrastructure continued to utilise Ballakinnish for storing construction based material. This has proved to be extremely beneficial to the operational requirements of the Department.
| Private |
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| I.O.M. Energy from Waste Facility |
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| Starter Units |
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Picture3: Area of Ballakinnish identified for material storage (3 acres) and surrounding notable features
In 2014 the DOI submitted a retrospective PA 14/00689 for change of use of 3 acres of land at the former nursery site is site, from market garden to material storage. The change was to allow the Department to store construction materials and excavated arising’s from two current projects in Douglas, namely;
Since 2014, the Department of Infrastructure has not received any adverse comments regarding the site and are unaware of any complaints regarding their operations at Ballakinnish.
The site has continued to operate as envisaged to support the stock of materials for the regeneration and promenade schemes. Since completion of these schemes it continues to be operated for other local sites including the Richmond Hill drainage improvements and the current Victoria Street works. Daily volumes of traffic have been reduced since the completion of the Promenade scheme and it is envisaged these will remain at a lower level than detailed in the original application.
Over the next 5+ years the Department has plans for further refurbishment of Douglas Promenade which will include;
Additionally the following highway and flood alleviation schemes are planned in the eastern area which will benefit from access to the Ballakinnish site for storage of materials;
Highways currently utilises the materials storage compound at Ballakinnish to supply all of its eastern construction sites. The number of vehicle movements into the main streets of Douglas and the surrounding areas are managed in an efficient manner from the Department’s depot rather than a wholesale supplier thus minimising the deliveries to the Island and reducing the number of deliveries required by the local suppliers to a town centre site. The environmental benefits of reducing construction traffic are a reduction in congestion, noise, pollution and carbon emissions. Return journeys from site can be used for waste removal. These processes also meet the Departments goals of introducing “just in time” delivery and lean management and following best practice outlined in the WRAP document “Using Construction Consolidation Centres to Reduce Construction Waste and Carbon Emissions”. Additionally, there is an added visual and societal benefit of minimising the quatinty of materials stored on town centre sites by maintaining smaller, cleaner sites and less fencing to obstruct public views.
The central location of the Ballakinnish site works particularly well for all projects on the east, central and southern parts of the Island, and is the only location where there is ample area to store the large stockpiles of paving, pipes, fittings etc. with easy access to the highway network for deliveries to and from the site. None of the Department’s other highways depots are of sufficient size to meet these needs. The Department has lost the facility to store materials at its main Ellerslie Depot as this land is now rented out to the private sector by the landowner.
close to the Energy from Waste facility to ease moving the waste to the Energy from Waste when required during the commissioning phase of the new SWI.
The location of the Ballakinnish site works particularly well for the temporary storage of the 20ft shipping containers, being across the road from the Energy from Waste facility. The site is secure with a lockable gate, and CCTV. The site had sufficient hardstanding for the 20ft shipping containers.
The hours of operation will reflect the current operating hours of the Departments working arrangements:
During commissioning access to the clinical waste maybe required outside these hours especially at weekends and later in the day when the plant is operational 24/7. Out of hours access to the site where possible will be kept to a minimum.
Vehicular and pedestrian access to Ballakinnish will continue from the A5 New Castletown Road. A safe area is provided for articulated vehicles off the highway before the locked gate requires access.
It is anticipated the gate will be locked at all times outside of the operating hours specified above. During operating times the site will be left vacant; security will be provided with CCTV cameras
Excavated arisings are only temporarily stored at Ballakinnish. The volume of material on site at any one time is kept to a minimum and is removed to a recycling depot or to tip on a monthly basis, or
The 20ft shipping containers will not be stacked, placed on hardstanding surface, and has the dimension as shown in Picture 4.
Picture4: 20ft shipping container dimensions
• 70 motor cars • 14 light goods vehicles • 3 articulated vehicles The proposed weekly vehicle usage for the material storage facility will average; • 50 light goods vehicles • 3 tipper lorries • 1 articulated vehicle The proposed weekly vehicle usage for the clinical sharps waste storage facility will average; • 1- 2 light goods vehicles
It is intended the LGV’s (2, 3 and 4 axle) visiting on a daily basis will be attending the facility during the operational hours stated in 2.1 above.
It is anticipated the four axle tipper lorries visiting site will do so fortnightly on one day (6 No.) between the hours of 8.30 and 3.30, Monday to Friday.
Articulated vehicles will bulk deliver materials approximately every 10 weeks. Deliveries will usually be carried out over two days, with multiple articulated vehicle trips between the hours of 09.00 and 17.00 Monday to Friday.
Drivers approaching the access are able to see the entry from a distance of at least 160m (the minimum distance stated in the Design Manual for Roads and Bridges) from the A5.
The new site entrance proposed in PA 14/00689/C was not developed. On review it was considered that the existing site access provided adequate sight lines for vehicles entering and exiting the site.
Predominately the materials to be stored will be inert natural stone, concrete and clay paving units. Materials required for activities such as drainage and ducting works, relaying tram tracks and fencing will also be stored at Ballakinnish.
Materials will be delivered to Ballakinnish on articulated lorries from either Douglas or Ramsey harbour. Once on site, the material will be unloaded using a site master excavator and placed into designated areas according to project requirements.
Any excavated arising’s stored at Ballakinnish will be brought to site on 2, 3 or 4 axle lorries depending upon the volume of material involved. All imported material will be free from any contaminants.
Collection of materials for the construction schemes will be done on a daily basis using a lorry. When there is a suitable quantity of excavated arising’s, these will be removed for recycling or to tip, using
The 20ft shipping container will remain static and will not be moved while there is clinical waste within the 20ft shipping container. The removal of the clinical waste and stacking of the clinical waste containers will be carried out following the requirements and controls within a Risk Assessment and Safe Working Procedure. After each removal of the clinical waste from the Dolav containers and appropriately stacked, the 20ft shipping container will be locked.
If a disturbance of the 20ft shipping container is noticed then the CCTV will be reviewed to assess the source of the disturbance and the police informed if the disturbance was from unauthorised access.
The vehicular activity will create noise. However modelling indicates that this will not be at a level to cause a nuisance to the occupants of properties adjacent to the site: Ballakinnish; Croyton, and Brookside. Using formula and charts issued by the Department of Transport UK, two simple noise calculations have been carried out.
A third calculation combines the two noise figures and determines the overall increase (if any) in noise resulting from the material storage facility. The results are summarised in the table below.
| Property<br><br> | Noise Level [L10(18hour) dB(A)] | Noise Level [L10(18hour) dB(A)] | Noise Level [L10(18hour) dB(A)] |
|---|---|---|---|
| Property<br><br> | Road | Site | Combined |
| Ballakinnish | 61.6 | 48.4 | 61.8 |
| Croyton | 65.6 | 41.5 | 65.6 |
| Brookside | 58.3 | 38.0 | 58.3 |
Table 1: Basic noises calculations
The table clearly shows the proposed material storage facility will have no noise impact on Croyton and Brookside and only a negligible impact on Ballakinnish. However these figures are for general road traffic and do not take into account any special devices such as reversing beepers.
To mitigate any noise pollution caused by reversing vehicles;
In the past 8 years there have been no complaints about noise nuisance from use of the site.
Dust is only likely to affect the property Ballakinnish. As with noise, to mitigate any impact from dust their storage will be furthest away from the house, in the north east corner of the site.
Generation of dust through vehicle movements particularly on unpaved roads can account for a significant proportion of dust nuisance which can be exacerbated in dry or windy conditions. To reduce dust created by vehicles, suitable dust suppression activities are carried out during periods of dry weather.
A number of methods to minimise dust caused by moving vehicles were initially considered by the Department, for example paving haul routes and installing a wheel wash. They were not proposed due to the low levels of dust likely to be created and the costs involved in installing them. In the past 8 years there have been no complaints about dust pollution. The DEFA Environmental Protection Unit visited the site to assess the need for a waste disposal licence and raised no concerns about the environmental impact of site operation.
Ballakinnish as a temporary clinical waste material storage facility will have a negligible impact on dust / air pollution due to the types of materials stored there. All the clinical waste will be in UN approved containers stacked inside 20ft shipping containers.
Generation of dust through vehicle movements particularly on unpaved roads can account for a significant proportion of dust nuisance which can be exacerbated in dry or windy conditions. Due to the low level of vehicle movement and the 20ft shipping containers will be on a hardstanding area there will be negligible impact on dust / air pollution due to vehicle movement.
Until 2007 the site operated as a Nursery, after which the nursery relocated and the site became derelict, leaving the site vacant with only limited evidence available of its previous use.
In 2010 the Department of Transport took possession of the site for use as a compound for the highway improvement scheme on Richmond Hill. To create the compound, excavated arising’s and soil were imported to build up the areas in between the concrete strips to make the site more usable.
The levelling of the site has been carried out without having any impact on the site boundaries or the surrounding fields. A rapid ecological survey on part of Ballakinnish site was undertaken in August 2021 (Appendix 2 MWT ‘Ecological Advice: Ballakinnish Nurseries, Braddan, Isle of Man’) This concluded that, while ‘it is a brownfield site, it contains valuable wildlife habitat for invertebrates and breeding birds and may be used by Common Lizard and Common Frog as terrestrial habitat.’ ‘As much of the site as possible should be preserved for its value to wildlife. In particular, field margins, hedgerows and scrub should be retained.’ This study did not identify any detrimental impacts of the current site use on the ecology of the site.
| Energy from Waste Facility |
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| Ballakinnish |
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Picture5: View of site and surrounding area from Richmond Hill
When the site operated as nursery it was visible from the A5 Richmond Hill, even more so during periods of dusk / darkness when it operated under floodlights (picture 7). The makeup and operation of the site as a storage facility means it is also easily identified from Richmond Hill.
As the proposal is temporary storage of clinical waste within single stacked 20ft shipping containers the visual impact is temporary and low.
Although The Department proposed initially to plant approximately 44 standard size trees along the western boundary of the site, this was not undertaken. The vegetation on the site was found to be both well established and enhancing local biodiversity. The colours of the materials stored are natural greys browns and greens, and the height of stored materials is low. Although visible from Richmond Hill the site it not formally developed ie built on. In the past 8 years there have been no complaints about the visual impact of the site or its operation.
The Department has lost access to land at Ellerslie Depot that it previously leased resulting in the loss of approximately 6,800m2 of valuable material and equipment storage space. Following the loss of parking area at Ellerslie, as well as the loss of registration for vehicles to be parked overnight at the former Vehicle Testing Centre in Braddan, Ballakinnish has been registered as an “O” Licence Operating Centre for parking of 12 Department vehicles associated with the construction works in the Eastern area. Currently up to 4 vehicles are parked on the site overnight.
Policy for provision of Depots for Highways The Department acknowledges the need for a strategy for provision of depots around the island. This includes permanent depots, as well as temporary depots to service area specific projects. The DoI produced its depot strategy in 2010 which identified the need for new regional depots but due to financial constraints has not progressed. It is envisaged that, when economic circumstances allow, this strategy will be revisited by the DOI with a view to identifying both permanent and possible temporary locations. This may involve joint or shared site uses.
In the short term the Ballakinnish site is needed for ongoing Departmental projects. In the event that planning permission is not granted for an extension of time, the Department is unlikely to be able to progress these projects due to increased cost and delay. The materials will need to be stored
The Department has reviewed alternative sites for the temporary storage of clinical sharps waste in 20ft shipping containers and considered them unsuitable, due to:
Logistically the walkway would be the preferred site as it is close to the working areas, minimizing haulage and travel time. However, given the large volumes of material to be stored and the general
public use of the area this is not considered to be a practical solution or acceptable on day to day safety grounds or visually given the tourist and recreational facility provided by the walkway. In addition, use of the promenade walkway would not be allowed during events such as TT, the Parish Walk, IOM triathlon, Manx Grand Prix, Junior Cycling Races & Manx Rally etc.
Picture6: View of site and surrounding area from Richmond Hill
This site is owned by the Department of Infrastructure and is currently up for sale. Private developers have expressed an interest in developing the site; subsequently the saleability of the site would be greatly reduced if an area of it was being used as a storage compound. Manx Development Corporation are looking at development options and have recently carried out site investigation works in preparation for design development.
Nobles Hospital Site This site has developed and is no longer available, and does not have the sufficient space for the quantity of 20ft shipping containers required and the site is not secure.
A further option for consideration is the Departments facilities at Jurby. Although near to Ramsey Harbour, it is too far away from Douglas (3 – 4 hour round trip) for it to be financially and environmentally viable for materials to be collected / deposited on a daily basis.
Fish Yards, Peel The DEFA owned fish yards in Peel is another location for consideration. As with Jurby the travelling distances and resulting inefficiencies rule this site out.
Old Meat Processing Plant, Tromode. This site has been developed and is no longer available.
Existing Depots Ellerslie Depot This site is no longer available.
Ballasalla The Department’s Ballasalla depot could be made available for material storage. Similar to Jurby this is a particularly poor choice of site due to the long haulage distance for initial material storage and collection for daily supplies to the sites. An average return journey time including loading and unloading would be in the region of 3-4 hours and would lead to working inefficiencies.
Hillberry A further Department depot is at Hillberry which again could be made available. However, access to this site is from the TT course. Visibility at the entrance is poor and the Department is trying to minimise the use of this depot for these reasons.
Privately Owned Sites Situated around Douglas are a number of privately owned industrial estates such as
All of these sites have suitable areas for the Department to use as a material storage facility. However they all charge a premium cost for usage and would not provide Government with value for money. As such no privately owned sites have been considered further.
Middle Park Recycling While middle Park Recycling facility is next to the Energy from Waste facility, Planning permission as a Waste Operations site with a Waste Disposal Licence it is privately owned. The financial cost for the temporary storage of clinical sharps waste would be in excess of £100,000 and require treasury approval for the funding during a time where the government is looking for efficiency
savings. Access to the site may be restricted to operational times that are not convenient during the commissioning phase.
The site is not allocated as a highways depot within the Area Plan for the East. It is within an area of high landscape value. General Policy 3 states that development will not be permitted outside of areas zoned for development. However there are exemptions. It is considered that proposed continued use of Ballakinnish site meets Policy GP3 (e) in that it is location-dependent development in connection with the provision of necessary services; and Policy GP3 (g) in that the development is of overriding national need in land use planning terms, and there is no reasonable and acceptable alternative. Spatial Policy 1 identifies that Douglas urban area ‘will remain the main employment and services centre for the Island.’ The Department is required to develop and maintain the infrastructure necessary support this location dependent Policy.
Our Island Plan incorporating the delivery of the economic strategy
In delivering ‘An Environment we can be proud of’ the Island Plan aims to
The Department projects serviced by the Ballakinnish Depot support these aims.
A copy of the decision notice for PA 14/00689/C is included in Appendix 1
The site has been operating over the past 8 years without complaint. There is a demonstrable and on-going need for the site to meet the operational requirements of the Department in the east of the Island. There are no alternative suitable non-commercial sites available for materials storage. A number were considered by rejected as being too;
Environmentally the facility will not significantly impact on the local surroundings.
It is acknowledged that the Department would benefit from a strategy for provision of operational depots both permanent and project specific. There is a need, as part of this strategy, to identify a suitable Depot in the east to service the infrastructure requirements of the capital and periphery. However, this is medium term objective and is subject to resources and funding availability. When Ballakinnish is no longer required it will be cleared of material and hardstanding, vacated and suitably landscaped.
Ballakinnish best meets the need for a material storage facility to support the Departments needs for the east and ongoing development works to Douglas Promenade. It has access onto the primary distributor network, is located away from residential areas, its proximity to Douglas Town Centre and minimal establishing cost provides significant financial and environmental benefits to all other considered locations.
Ballakinnish best meets the need for the temporary storage facility of clinical sharps waste to support the Departments needs while the new Secondary Waste Incinerator is being built and commissioned. It has access onto the primary distributor network, is located away from residential areas, and
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