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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. 23/00750/B Applicant : Mr Adam Cooke Proposal Erection of two wind turbines Site Address Field No. 414697 Ballaman Ballnahowe Road Port Erin IM9 6JF
Case Officer :
Hamish Laird Photo Taken :
05.09.2023 Site Visit :
05.09.2023 Expected Decision Level Planning Committee
Recommendation
Recommended Decision: Permitted Date of Recommendation 30.05.2024
Reasons for Refusal
R : Reasons for Refusal O : Notes attached to reasons
R 1. The proposed development is unacceptable because it would give rise to views of the wind turbines from Port Erin and the surrounding area, particularly Bradda Head from the Meayll Circle Ancient Monument to the north and from the Meayll Circle Ancient Monument to the south resulting in an unacceptable degree of visual intrusion and harm to the character and appearance of the countryside and surrounding area in which the turbines are proposed to be sited. This would be emphasised by the sites location within an area zoned as High Landscape or Coastal Value and Scenic Significance. In the Adopted Area Plan for the South (2012), which is informed by the Isle of Man Landscape Character Assessment, July, 2008; Landscape Proposal 10 states: "Any additional new built development on the Meayll Peninsula, other than very limited development near its northern edge at the former Marine Biological Station, should be avoided as such development would adversely affect the largely unspoilt character and appearance of the Peninsula and/or would diminish its role in providing a vegetated, undeveloped backdrop to Port Erin, Port St Mary and Cregneash." Furthermore, Landscape Proposal 11 states: "Should the opportunity arise, the radio beacon on Cronk ny Arrey and other communications apparatus on the Meayll Peninsula should be removed or, if necessary, replaced by more modest and less intrusive structures." The erection of the 2 No. proposed wind turbines would run counter to this long-standing advice and as such is contrary to it, and the provisions of Strategic Objective 3.3b); Strategic Policy 4b); General Policy 2 c); and, Environment Policies 1 and 2 contained in the Isle of Man Strategic plan 2016.
R 2. It has not been demonstrated that the installation will not adversely affect the operation of the Isle of Man Airport with a resultant potential significant harm to aircraft safety, contrary to Transport Policy 10 of the Strategic Plan. __
Interested Person Status - Additional Persons
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It is recommended that the owners/occupiers of none of the following properties should be given Interested Person Status as they are considered not to meet the requirement of being located within 20.0m of the site boundary; and, as such do not have sufficient interest in the subject matter of the application to take part in any subsequent proceedings mentioned in Article 4.2:
Camelot 8 Tromode Close Douglas The Hon. Juan Watterson BA(Hons) BFP FCA CMgr FCMI FRSA SHK Speaker of the House of Keys. 28 Erin Way, Port Erin Sea View Bradda Glen Port Erin 5 Bradda Glen Close Port Erin 20 Royal Shore Apartments Promenade Port Erin Appt 1, Bradda Court, Port Erin Appt 5, Bradda Court, Port Erin Baycliffe, Tower Road, Bradda west, Port Erin 17 Royal Shore Apartments Promenade Port Erin 1A Princess Towers Promenade Port Erin Manchester House Bradda West Road Port Erin 7 Cronk Y Thatcher, Colby, IM9 4LN 167 Clapham Road, London SW9 0PU Lhie ny Greiney, the Darragh, Port Erin Ballaqueeny Cottage, Four Roads, Port St Mary - Bay Estates Ltd, owner of Car-Y-Touree, Balnhowe Whindyke Bradda West Road PORT ERIN Shilley Ny Marrey, Castletown Road, Port St Mary The Coote Ballnahowe Road Port Erin Car-Y-Touree Cottage, Balnhowe Shilley ny Marrey Castletown Road Port St Mary Brook Cottage, Bradda Road, Port Erin 9 Aigh Vie, Main Road, Colby
The above persons, therefore, do not satisfy all of the requirements of paragraph 2 of the Department's Operational Policy on Interested Person Status (July 2021).
It is recommended that the following Government Departments should be given Interested Person Status on the basis that they have made written submissions that relate to planning considerations: Manx Natural Heritage Department of Infrastructure, Airfield Operations, Isle of Man Airport, Ballasalla, IM9 2AS __
Officer’s Report
THE APPLICATION IS BEFORE COMMITTEE DUE TO THE NUMBER OF REPRESENTATIONS RECEIVED
1.0 THE SITE
1.1 The site comprises part of Field No. 414697 at Ballaman, Ballnahowe Road, (known as Darragh on Google Street View and Mull Road on the submitted turbine location plan). It is located on high ground in the countryside on the south side, and outside the settlement boundary of Port Erin. It lies close to and to the west of a cluster of buildings which accommodates Ballaman. The main house on the holding is substantial originally having been a prominent house and then extended significantly over time. To the rear (south) of this are farm
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cottages, farm offices and a helicopter hangar. The site lies approx. 800m south of Port Erin Harbour; and, 400m to the west of the Irish Sea on the south west coast of the Island.
1.2 The land in this area rises up from sea level at Port Erin with the highest point being Meayll Circle 600m to the south, before dropping back down to Spanish Point which is the most southerly point on the Island, with the Calf of Man located approx. 2km to the south-west of the site.
1.3 The site is visible from a very wide area, from Bradda Head through Surby, Ballafesson to Port St. Mary including a view downwards from the Meayll Circle Ancient Monument which is a prehistoric burial of late Neolithic or early Bronze Age.
2.0 THE PROPOSAL 2.1 The full application is for the erection of 2 No. horizontal axis wind turbines. The turbines would have a hub height of 9.0 metres, and a maximum tip height of 13 metres. They would be mounted on tubular steel towers without guy wire supports. The spacing between the two turbines would be no less than 25 metres. The wind turbines would be for the provision of electricity to Ballaman only, and would be connected by a cable running from Turbine 2 (T2) to the house's plant room, for an approximate distance of 90 metres. The cable would be laid below ground at a depth of not less than 1 metre.
2.2 The wind turbines would be grey in external colour, in common with most commercial wind turbines, but could - subject to imposition of a planning condition - be repainted with any external finish. They would typically have pad foundations measuring approximately 2.6m × 2.6m × 0.9m depth, although a 'root' or piled foundation option is also available. Ground conditions at the site indicate that a 'pad' foundation would be adequate. The turbines would be sited at an elevation of approx. 97m AOD, and sited approx. 100m west of Mull Road.
2.3 The applicant advises that a range of wind turbine models may be suitable for the Site, and the final choice of turbine model would be selected through a competitive procurement process. This means that no actual design details of the actual turbines to be erected, details of their electrical output, and no assessment of their actual noise output have been provided. The design life of the turbines sought is at least 25 years. This is standard for small- scale wind turbines. After this period, the turbines can be decommissioned and the land reinstated to its original condition, or a further application for 'repowering' could be submitted to the Department.
2.5 Subsequent to comments received from DEFA Ecosystems Policy Officer, an assessment of the possible or likely impact on birds has been provided to accompany the application.
2.6 The application is supported by a full set of plans and drawings; a Preliminary Ecological Appraisal Report by Atmos Consulting Ltd dated January, 2024; A Shadow Flicker Plan; Noise Contour Plan; A Terrain Section to the Airport; Planning Statement; Constraints Plan; and, a Ballaman Potential development Areas Plan; plus various Viewpoints (16 in total) and a Viewpoints Plan.
2.7 The Site Layout Plan was amended on 8th May, 2024, to reflect comments received from DEFA Ecosystems Policy Officer. The proposed site of the wind turbines was shown as being moved slightly away from the sites boundary hedges with no changes to the area of the site edged red. The change reflects the 30m standoff from hedges that Ecosystems Policy Officer requested.
3.0 PLANNING HISTORY 3.1 The site has been the subject of a number of applications which have sought and gained approval for alterations and extensions of the house and the creation of storage and hangar facilities for the applicant's helicopter all of which have increased the impact of the development
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albeit arguably improved the quality and character of the buildings on the site. Alterations have also been approved to the two entrances to the site from the Balnahowe Road. None of these are considered relevant to the consideration of the current application. What has approval is what can be seen on site or thereabouts.
3.2 PA 14/00632/B for the erection of three 10 Kw wind turbines in Field 414526 at Ballaman Refused for the following reasons: 1. It has not been demonstrated that the installation will not adversely affect the operation of the Isle of Man Airport with a resultant potential significant harm to aircraft safety, contrary to Transport Policy 10 of the Strategic Plan.
The visual impact would be so harmful on the surrounding environment, from Port Erin and its surrounding hinterland and particularly as viewed from the coastal footpath and the higher perspective from the Mull Circle as not to be outweighed by the environmental benefits of the scheme and would therefore be contrary to Environment Policies 1 and 2 and General Policy 3 all of the Strategic Plan and Landscape Proposal 10 of the Area Plan for the South.
3.3 The Decision Notice was dated 06.04.2017. No appeal was received.
3.4 22/00397/B - Installation of ground mounted solar array at Ballaman - site to south of Ballaman House - permitted - 7/9/22. This site lies adjacent, to the west and north of the current 23/00750/B application site for 2 No. Wind Turbines.
4.0 PLANNING POLICY 4.1 The application site is not within an area designated for development, under the Isle of Man Development Plan Order 1982. The site is not within a Conservation Area; but is within an area zoned as High Landscape or Coastal Value and Scenic Significance.
4.2 Under the Landscape Character Assessment the site falls within F7 The Lhen undulating lowland plain, which is characterised as 'an area of predominantly arable farmland, which comprises a mixture of small to medium, relatively regular rectangular fields... The landscape is flat to gently sloping and falls from north to south towards the sea. At the western end of the area, a low ridge (or spur) rises to meet the coast, and overlooks Cronk y Bing, within the adjacent area of Smooth Coastal Strip (at which point, the coastline falls more steeply down towards the sea than within shallower areas of foreshore further to the east)... Settlement pattern is scattered and relatively isolated, with several single farmsteads and houses (many in traditional vernacular style). Other than these buildings, there are few vertical elements within the area. Open and glimpsed views, northwards to the sea (and of areas of adjacent Smooth Coastal Strip) can be gained from several locations along the A10, and views southwards are framed by a distant backdrop of Upland horizon...'
4.3 The Strategic Plan contains advice on the installation of renewable energy facilities as follows: Paragraph 12.2.8: "The Department is fully supportive of the need to secure greater energy efficiency in new and existing development and has recently introduced additional energy efficiency requirements in the Building Regulations 2003."
4.4 In the strategic Plan 2016, the following Policies are of relevance:
General Policy 2 indicates that: "Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development: (a) is in accordance with the design brief in the Area Plan where there is such a brief; (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them;
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(c) does not affect adversely the character of the surrounding landscape or townscape; (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses; (e) does not affect adversely public views of the sea; (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks; (g) does not affect adversely the amenity of local residents or the character of the locality; (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space; (i) does not have an unacceptable effect on road safety or traffic flows on the local highways; (j) can be provided with all necessary services; (k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan; (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding; (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and (n) is designed having due regard to best practice in reducing energy consumption."
Environment Policy 1 states: "The countryside and its ecology will be protected for its own sake. For the purposes of this policy, the countryside comprises all land which is outside the settlements defined in Appendix 3 at A.3.6 or which is not designated for future development on an Area Plan. Development which would adversely affect the countryside will not be permitted unless there is an over-riding national need in land use planning terms which outweighs the requirement to protect these areas and for which there is no reasonable and acceptable alternative."
Environment Policy 2 states: "The present system of landscape classification of Areas of High Landscape or Coastal Value and Scenic Significance (AHLV's) as shown on the 1982 Development Plan and subsequent Local and Area Plans will be used as a basis for development control until such time as it is superseded by a landscape classification which will introduce different categories of landscape and policies and guidance for control therein. Within these areas the protection of the character of the landscape will be the most important consideration unless it can be shown that: (a) the development would not harm the character and quality of the landscape; or (b) the location for the development is essential."
Energy Policy 4 states "Development involving alternative sources of energy supply, including wind, water and tide power, and the use of solar panels, will be judged against the environmental objectives and policies set out in this Plan. Installations involving wind, water and tide power will require the submissions of an Environmental Impact Assessment."
4.4 Environment Policy 24: "Development which is likely to have a significant effect on the environment will be required: i) to be accompanied by an Environmental Impact Assessment in certain cases; and ii) ii) to be accompanied by suitable supporting environmental information in all other cases."
4.5 Appendix 5 sets out further information and lists developments which will automatically require an Environmental Impact Assessment, including: (c) Energy industry o Thermal power stations and other thermal installations o Surface storage of natural gas o Underground storage of combustible gases o Surface storage of fossil fuels
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o Industrial briquetting of coal and lignite o Installations for the harnessing of wind power for energy production
4.6 The means of assessing the impacts (good and bad) of a proposed development on the environment, prepared by, or on behalf of, the developer/applicant. An EIA should aim to ensure that the planning decision is made in the knowledge of all the likely environmental effects of the development, and of the proposals for mitigating adverse effects and enhancing positive effects.
4.7 Transport Policies T4 and T7 relating to access to the site from the road network; and, on- site parking and turning provision, are of relevance. Transport Policy T10 relates to the location and nature of development in and around the Island's airports, airfields, and air traffic control sites will be controlled in a manner which ensures that the safe and efficient use of these facilities by aircraft is not compromised.
4.8 Other relevant policies and strategies;
Climate Change Act 2021 completed its passage through Tynwald in April 2021 and subsequently received Royal Assent in December 2021. The Act requires a statutory five-year Climate Change Plan to be in operation at all times, ensuring a clear direction for the Island to achieve net zero carbon emissions by 2050.
The Climate Change Action Plan 2022-2027 was subsequently produced and published in July 2022 and outlines the actions Government must take to cut emissions over the next five years, so the Island remains on track to be net zero by 2050. The plan assigns a percentage emission reduction target to six policy areas, including energy, transport and agriculture that must be met. Some of the major actions include: o The provision of carbon neutral electricity supply by 2030 o Bringing forward building regulations to ensure 97% energy efficiency in new buildings o Seeking to bring forward a ban on fossil fuel heating systems in new builds to 2024 o The installation of 20MW of local renewables by 2026 o Future introduction of further support for homeowners and tenants to aid the transition o The setting of a new interim emissions target of 35% by 2030.
5.0 REPRESENTATIONS
5.1 Arbory and Rushen Parish Commissioners (24/7/23) comments: "In relation to the following application for wind turbines at Ballaman, the Commissioners felt this was overdevelopment of an already highly developed site. It was further felt that the development would have a visual impact so harmful on the surrounding environment as not to be outweighed by the proposal's environmental benefits and be contrary to the relevant Environmental and General Policies and the relevant Landscape Proposal of the Area Plan for the South."
5.2 Port Erin Commissioners (9/8/23) comments: "The Board of Port Erin Commissioners considered the above application at its meeting held on 8 August 2023 and has resolved to request interested party status due to the proximity and potential impact to the village district of Port Erin. The Board will also seek to consult with residents prior to submitting a formal view on the proposals."
5.3 No further comments had been received from Port Erin Commissioners by the Report drafting stage (29/5/24).
5.4 Doi Highways Services (14/7/23) comments:
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"23/00750/B - After reviewing this Application, Highway Services HDC finds it to have no significant negative impact upon highway safety, network functionality and /or parking, subject to a construction traffic management plan being agreed before construction outlining routing, manoeuvring and access of large vehicle construction traffic."
5.5 DEFA ecosystems Policy Officer (24.3.24) comments:
"The Ecosystem Policy Team currently object to this application.
There is a significant amount of scientific evidence that shows that poorly positioned and inappropriately-sized wind turbines, even relatively small turbines, can have hugely detrimental impacts on wildlife, particularly to birds and bats from collision deaths. As such, ecological reports and assessments should typically form a fundamental component of planning consents involving wind turbines. However, this consideration does not appear to have been undertaken for this application.
The Ecosystem Policy Team understand the importance of, and is very supportive of utilising renewable energy sources as part of the solution for climate change, which in itself will continue to have devastating impacts on wildlife. However, this does not negate the need to make thorough considerations into the potential impact of local wind turbine installation and the requirement to mitigate any impacts to ensure that installation will not result in a net loss for biodiversity on site.
The importance of ecological surveys is even more important due to the proximity of the site to cliffs used by nesting seabirds, use of the site by choughs, likely use of the site by birds of prey, the proximity to Port Erin Bay Marine Nature Reserve (MNR), proximity to Meayll Coast Wildlife Site, and relative proximity to the Calf of Man Bird Observatory which is a site of importance for birds, particularly migrating birds, on the Isle of Man.
Marine Nature Reserves are designated under the Wildlife Act 1990 for the purposes of conserving marine flora, fauna, geological or physical features of special interest, or providing opportunities to study or research such features. Port Erin Bay MNR was designated in 2018 with a list of conservation features (habitats and species) which form the basis of the individual MNR designation. For Port Erin MNR, these conservation features included the birds shag, fulmar, gannet and gulls. Gulls in particular from this list, are mostly likely to be impacted by wind turbines in this area, as they often forage and roost on coastal grassland areas. Some species of gull are Red listed on the Birds of Conservation Concern on the Isle of Man, and are therefore are of greatest conservation concern.
It was acknowledged in the 2014 Planning application for Ballaman that 2 pairs of chough regularly bred within 500m of the proposed turbine site, that there is also a significant chough population in the wider area, and that the fields within the site are likely to be used by feeding and commuting chough. As such, it was determined that they could be at significant risk from collision with turbine blades.
The Ecosystem Policy Team does not currently have possession of the bird data for this area, but we are aware anecdotally that large numbers of chough are still present in the local area and it is likely that chough are still breeding in the vicinity and therefore they will need to be thoroughly considered. Red-billed Chough are listed on Schedule 1 of the Wildlife Act 1990, and amber listed on the Birds of Conservation Concern on the Isle of Man. It is also important to note that the Isle of Man is a stronghold and home to a significant proportion of the UK's chough population, which is extremely limited in its range.
Looking at the previous application for the turbines at Ballaman, it seems that chough were the only bird species given consideration, but we now deem this inadequate and believe that much greater bird consideration is required, including use of the site and likely impacts upon birds of
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prey. Meayll Coast Wildlife Site is located around 300m away from the proposed turbine site. Wildlife sites, though not statutorily designated or recognised by law, are nonetheless sites of high wildlife value which should be recognised through the planning system (see Environment Policy 4 below). More information about Wildlife Sites can be obtained from the Manx Wildlife Trust. Wildlife sites are selected on the basis of a set of criteria and in the case of Meayll Coast, the criteria which the site fulfilled included the following: C10. All stretches of maritime hard cliff that supports important colonies of seabirds. B1. All important Manx sites for all bird species (seabirds excluded, see below) for which the Island is known to hold, or has recently held, at least 0.5% of the British Isles breeding and/or wintering populations, ie:
We therefore request that a Preliminary Ecological Appraisal (PEA), adhering to CIEEM (2017) Guidelines for Preliminary Ecological Appraisal (2nd edition), be undertaken by a suitably qualified ecological consultancy and a report be submitted to Planning prior to determination of this application. The PEA must incorporate breeding, wintering and commuting bird surveys and bat activity surveys.
Should the PEA and surveys determine that habitats and species of importance are present and will be negatively impacted by the installation of the wind turbines then a mitigation plan for their protection during and after the development, as well as any necessary avoidance and compensation measures, must be submitted to the Department for written approval prior to the determination of the application. Surveys should be undertaken in line with best practice guidelines. The recommended mitigation measures may include the relocation of the turbines on site.
Submission of reports prior to determination of this application is in line with UK best practice guidelines, as referred to in Section 9.2.4 of the British Standard Biodiversity - Code of Best Practice for Planning and Development (BS 42020:2013). Which states: "The presence or absence of protected species, and the extent to which they could be affected by the proposed development, should be established before planning permission is granted; otherwise all material considerations might not have been considered in making the decision. The use of planning conditions to secure ecological surveys after planning permission has been granted should therefore only be applied in exceptional circumstances, such as where original survey work will need to be repeated because the survey data might be out of date before commencement of development, etc." Further relevant information in relation to ecological surveys on the Isle of Man, and DEFA Policies can be found here;
Isle of Man Strategic Plan 2016 Strategic Objective 3.3 (b) To protect, maintain and enhance the built and rural environment (including biodiversity) (i) To protect the countryside and coastal areas for their own sake.
Strategic Policy 4: Proposals for development must: (b) protect or enhance the landscape quality and nature conservation value of urban as well as rural areas but especially in respect to development adjacent to Areas of Special Scientific Interest and other designations;
General Policy 2:
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Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development: (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;
Environment Policy 4: Development will not be permitted which adversely affect: (b) species and habitats of national importance: (i) protected species of national importance or their habitats; (ii) proposed or designated National Nature Reserves, or Areas of Special Scientific Interest; or (iii) Marine Nature Reserves (c) species and habitats of local importance such as Wildlife Sites, local nature reserves, priority habitats or species identified in any Manx Biodiversity Action Plan which do not already benefit from statutory protection, Areas of Special Protection and Bird Sanctuaries and landscape features of importance to wild flora and fauna by reason of their continuous nature or function as a corridor between habitats. Environment Policy 5: In exceptional circumstances where development is allowed which could adversely affect a site recognised under Environmental Policy 4, conditions will be imposed and/or Planning Agreements sought to: (a) minimise disturbance (b) conserve and manage its ecological interest as far as possible; and (c) where damage is unavoidable, provide new or replacement habitats so that the loss to the total ecological resource is mitigated.
Managing our Natural Wealth, The Isle of Man's First Biodiversity Strategy 2015
Strategic Objective 2 By 2025 Government will lead by ensuring biodiversity conservation is being considered in all relevant areas of policy and decision-making, actively encouraging good practice and adopting all appropriate incentives to support biodiversity.
Government leading by example Action 7
By 2022 embed proper consideration of biodiversity and ecosystem services in all relevant policy and decision-making to facilitate Government's commitment to biodiversity.
Site protection Action 19 From 2016, when assessing developments on or adjacent to protected sites, there will be increased consideration of biodiversity and environmental sustainability. Habitat loss action 21 DEFA will continue to promote a policy of 'no net loss' for semi-natural Manx habitats and species and ensure that unavoidable loss is replaced or effectively compensated for.
5.6 Manx Natural Heritage (19/7/23) comments:
"I write on behalf of Manx National Heritage ('MNH'), whose statutory responsibilities pertaining to the protection of the cultural and natural heritage of the Isle of Man are defined under the terms of the Manx Museum and National Trust Act.
Having read through the briefing notes made in the ecological mitigation strategy which was submitted in January 2017, in order to support a previous application for wind turbines at Ballaman, it is clear that the area of proposed development is important to bird life, particularly red billed choughs. This ecological mitigation report proposes a small number of strategies that
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will deter red billed choughs from the immediate area surrounding the turbines which we would like to see incorporated into any future approval.
We also have further concerns that the application does not consider an up to date appraisal of bird migratory routes for the site, especially as it is in such close proximity to the Calf of Man which is a known migration hot spot for birds. We would also like to see that correspondence with the Manx Bat Group has taken place in order to rule out any potential effects on bat feeding or migratory routes.
Whilst MNH support the principle of renewable energy we would like to see further information requested above, regarding avian and bat migration routes, in order to be able to make an informed decision about this application. We very much urge the applicant to contact the relevant organisation on the Island such as Manx Bat Group and Manx BirdLife before proceeding with this proposal."
5.7 Isle of Man Airport - Airfield operations (3/8/24) comments: "We would like to register the Airport's formal interest in this proposed development on the grounds of flight safety. We have been working in conjunction with the developer. We have undertaken a physical safeguarding assessment and are satisfied that the current proposal does not penetrate any of our protected surfaces. We would, however, require a specialist technical safeguarding assessment undertaken at the cost of the applicant to prove that the proposal has no effect on our navigational aids as a condition of any planning consent."
5.8 THIRD PARTY REPRESENTATIONS PA23/00750/B - 2 Wind Turbines at Ballaman, Third Party Representations
SUPPORT o Camelot 8 Tromode Close Douglas - I own a flat on Port Erin prom ,Ocean castle drive , Imperial heights . I have no objection
OBJECT o Car-Y-Touree Cottage, Balnhowe - 220 metres to the south-east of the proposed site. No EIA Noise form turbines will be 40dB(a) at Car-y-Touree Visual impact Several footpaths used by ramblers whose visual experience would be negatively impacted by the visibility of the turbines and noise emissions therefrom Negative impact on birds from the Turbines The negative aspects of the development would outweigh the low level, intermittent power generated by the turbines.
o Car-y-touree Cottage, Ballnahowe, Port Erin
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o 28 Erin Way, Port Erin - What and who and how many local people will these two eyesores benefit? Not convinced of any beneficial value to port Erin residents.
o Sea View Bradda Glen Port Erin - Wind turbines would be an eyesore and may also have a serious effect on bird life. They would also be between the Calf of Man bird observatory and the main island and there could be danger to the migratory birds.
o 5 Bradda Glen Close Port Erin - This will be very unsightly in an area of outstanding natural beauty - Port Erin is already becoming very overdeveloped.
o 20 Royal Shore Apartments Promenade Port Erin -
o Appt 1, Bradda Court, Port Erin - Ballaman is a blot on the lands cape with or without planning permission. The turbines rea a step too far.
o Appt 5, Bradda Court, Port Erin - I object to the wind turbines for the following reasons:- The visual impact these will have on an area of outstanding beauty which needs protection, being home to the ancient burial ground at Meayll Hill and a UNESCO World Heritage Site. The severely detrimental effect on wildlife, flora, fauna and bird life. A severely negative contribution to the environment, being visible and dominating the sky line, from Bradda Head, Port Erin, Cregneash, the Coastal Path, The Sound and The Calf. If this application were to be approved a precedent would be in place for every household in the Island to install wind turbines on their properties. Totally ruining the feel of an Island that prides itself on its beautiful, historic links with the past - for example, would Laxey Wheel be as charming, backed by a sea of wind turbines? I realise I am past the deadline for my objection, I have been off Island. However, please may I ask that you could consider my objections?
o Baycliffe, Tower Road, Bradda west, Port Erin 1 Damage to landscape Character and visual impact 2 Inappropriate over development. 3 Long term damage to the local economy due to fewer tourists coming to the area because 1 of the 2 headlands framing Port Erin would be despoiled and would reduce Port Erin's visitor appeal. 4 Adverse cultural impact - Impact on Bronze Age circle at Meayll Hill and views from Meayll Hill are uninterrupted and spectacular, towards the green Bradda Headland , across Port Erin Bay. 5 Safety issues regarding helicopter movements 6 Precedent - would lead to further wind turbine development
o 17 Royal Shore Apartments Promenade Port Erin - (1) Impact to Wildlife We learned that there's far less seagulls over the years in Port Erin and we should protect their existence by not intefering with their nesting sites near Ballaman. We should work together by giving birds space to breed and not putting up wind turbines that could kill them. (2) View destruction and degradation Putting up wind turbines will be an eyesore and visual pollution on the natural beauty of Port Erin. This would degrade the landscape aesthetically. We should not spoil the beautiful hill along the bay. We should restrict wind turbines in imposed areas like Port Erin which is UNESCO Biosphere that's protected in law.
o 1A Princess Towers Promenade Port Erin -
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"This installation would spoil a protected scenic area and culturally important landscape. Adversely affect wildlife both directly via collision as well as indirectly due to changes in noise pollution and air pressure causing habitat loss and reduce survival rates. We as an island are trying to attract and increase the recovery of vulnerable species, numbers are down due to various reason, this I fear will only help continue this trend. The island is one of the few places that has no pylons or wind turbines which attracts tourism and benefits residents. I appreciate the need for clean energy but this installation seems to benefit just one person, the applicant."
o Manchester House Bradda West Road Port Erin
o Lhie ny Greiney, the Darragh, Port Erin Our main reason is the visual impact and amenity in an area of outstanding beauty and huge historic significance for the Isle of Man. One of the greatest assets of the Isle of Man from both a quality of life and visitor economy is the appeal of our natural and unspoilt environment, especially coastal aspects. Ballaman's location is coastal and highly visible from a wide area in the south and siting these turbines will create a significant and negative visual impact.
The Meayll Circle is one the Islands most outstanding neolithic sites. The chambered cairn is recognised as one of the most exceptional within the British Isles. Its openness and rugged appearance is of vital archaeological importance and should be conserved in its most natural environment. We also have concern regarding the noise element that is generated from turbine activity and believe consideration must be given to the potential change in flight path for the personal helicopter housed at Ballaman. Not to mention potential effect on Ronaldsway flight radar and navigation. One final point of concern is birdlife. The area is awash with numerous varieties of seabirds. One tourist recently told me they spotted some 27 different types within one day. Just the other day I spotted two Ravens with a chick that was a joy to view soaring above Port Erin bay and then seen them head to a nest near Ballaman. Turbine's are an inherent danger to any birdlife. Lastly we noted previous similar application of April 2017 and decision notice to refuse was based on two issues. Namely Transport policy 10 and Environment Policies 1 and 2 and General Policy 3 all of the Strategic Plan and Landscape Proposal 10 of the Area Plan for the South. According to your Senior Planning Policy Officer "since this (2017) determination there have been no changes in planning policy in either the (Southern) Area Plan or Strategic Plan that would constitute a change in policy regarding wind turbines". Therefore we respectfully believe this application should also be refused
o Ballaqueeny Cottage, Four Roads, Port St Mary - Bay Estates Ltd, owner of Car-Y- Touree, Balnhowe - 220 metres to the south-east of the proposed site. No EIA Noise form turbines will be 40dB(a) at Car-y-Touree Visual impact Several footpaths used by ramblers whose visual experience would be negatively impacted by the visibility of the turbines and noise emissions therefrom Negative impact on birds from the Turbines The negative aspects of the development would outweigh the low level, intermittent power generated by the turbines.
o Whindyke Bradda West Road PORT ERIN
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of Man. Two 12m wind turbines will have a significant visual impact on this sensitive coastal location, and they would be visible from an extensive area of Port Erin and Bradda Head and the Coastal Path. In addition, new studies find that night-time 'swoosh' sound from wind turbines is also likely to be heard by neighbouring residents up to five times more often than during day-light hours, depending on wind direction, season and wind farm distance. When coupled with the night time light pollution from the constantly changing coloured floodlighting of the house the visual appearance & tranquil nature of this rural location is being significantly compromised. 2. Impact to Wildlife The turbine blades would be a great danger to the many sea birds which nest in the nearby cliffs. 3. Misleading Green Claims The Applicant seeks to emphasise the "Green Credentials" of the Application, however from the information provided I believe the proposed turbines will not be feeding into the national grid however instead they will be for the benefit of just one individual, sadly at the expense of the whole community. An overall view is that the visual, audible impact one the countryside and the impact on the local birdlife, I believe this proposal would potentially impact the viability of the IoM continuing as a UNESCO site.
o Manchester House Bradda West Road Port Erin - 1. Unacceptable Visual Impact in Open Countryside 2. Potential Impact on Local Seabird Population 3. Unacceptable Impact on the Setting of Archaeological Remains on Mull Hill and Meayll Peninsula 4. Potential Impact on the Air Navigation Radar for the Isle of Man (Ronaldsway) Airport 5. Safety Concerns about Operation of Helicopters from Ballaman Currently the private helicopters regularly using Ballaman usually approach the helipad from the coastal side. If the wind turbines are erected, I believe that more flights will approach over Port St Mary and Port Erin to avoid the turbines - this will result in an increase in the noise and disturbance from the helicopters already being experienced by the residents of Port St Mary and Port Erin. Our concerns are further heightened by recent plane crash at Bradda Head. 6. Precedence Created for Onshore Wind Farms in the Isle of Man 6. Precedence Created for Onshore Wind Farms in the Isle of Man 7. Concerns about the Information Supplied with the Planning Application a) The wind turbines are described as being 13m in height, this is 43 feet high or thereabouts, yet the drawings of the wind turbines show different dimensions. b) How many wind turbines are proposed - the application form states two yet the planning statement says three. c) Using the above measurements, the visual impact drawings from selective viewpoints appear to be inaccurate. The wind turbines appear to be too small when compared to the existing buildings at Ballaman. Also their visual impact is diminished as they are shown as faint images which blend into the background. The applicant should be asked to prepare new accurate visual drawings and photomontages. d) Due to the nature and location of the proposal an Environmental Impact Assessment should have been submitted with the Planning Application in accordance with Strategic Plan Environment Policy 24:- "Development which is likely to have a significant effect on the environment will be required: i) to be accompanied by an Environmental Impact Assessment in certain cases; and ii) to be accompanied by suitable supporting environmental information in all other cases." The accompanying list of proposals requiring an Environmental Impact Assessment is set out in the Strategic Plan Appendix 5, which states:- "It is proposed that the following types of development would require EIA in every case:...Installations for the harnessing of wind power for energy production". As there is no Environmental Impact Assessment, the applicant has failed to demonstrate which alternative sites have been considered. I do not believe that the planning statement and
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accompanying documents satisfies the legal requirement for an Environmental Impact Assessment. In addition I understand that the planning application site notice has been placed behind one of the statues in the grounds of Ballaman and is not clearly visible from the public highway on Ballnahowe Road. Given the numerous contradictory errors within the planning application and documents, and the failure to display the yellow site notice correctly, I would like to query whether this is a valid planning application and request that the contradictions highlighted should be clarified and the 21 day consultation period should be extended.
o Brook Cottage, Bradda Road, Port Erin - The site has been the subject of a number of planning applications over the years, including for wind turbines, and is now a massive complex of buildings, including a helicopter hangar and heliport. Previous applications 14/00632/B for wind turbines submitted 214/6/14, and a slightly amended on eon September, 2016, have previously been refused. The proposed wind turbines on the Mull Peninsula in an area of exceptional natural beauty would be visible from many angles and for several miles, and would dramatically alter the character of the area and may diminish the natural charm that draws people to this rural countryside. The turbines will only provide power for the applicants home and not for any communal benefit via the national grid Endorse Arbury and Rushen Commissioners view that this is an overdevelopment of an already highly developed site, and the visual impact vis so harmful on the surrounding environment that its environmental benefits do not outweigh the visual harm that would be caused as a result of the development.
o The Coote Ballnahowe Road Port Erin -
o Shilley Ny Marrey, Castletown Road, Port St Mary -
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Site of Great Natural Beauty - The turbines pose a threat to the Islands status as a UNESCO Site; Wildlife and Seabirds - the blades will pose a threat being so close to the calf of man and disturbance arising from construction; Over development of the site Historic and Archaeological impact - Views form Mull Hill Stone Circle and Meayall Peninsula would be significantly disrupted Safety issues regarding helicopter movements Precedent Contrary to government Policy Unnecessary - they would only serve Ballaman which already has an electricity supply and electricity usage can be controlled would be a waste of valuable resources
o Shilley ny Marrey Castletown Road Port St Mary - The site is not remote, it is an area of outstanding natural beauty and is enjoyed by residents and tourists alike. The island is a Unesco site. It is close to a Historical and Archaeological site - Mull Hill stone circle and Meayll Peninsular are significantly important. There will be a negative impact on wildlife and birdlife, both resident and migratory species. Both by the building works and the blades of the turbine. The site is already vastly overdeveloped, impacting on beautiful costal views, dark skies tourism, noise and UNESCO status. This planning application is not in line with Government policies and strategies or the Southern Plan. Precedent. Once allowed it will be difficult to prevent other developments in sensitive areas. The turbines are non-essential, as Ballaman has electricity supply and is another example of superfluous waste at this site. The planning application contains many inconsistencies eg heights of turbines and the drawings and images are imprecise and unreliable. The Planning application notice was badly displayed. The notice could not be read from a public highway.
o 9 Aigh Vie Main Road Colby - Threat to birds and bats Over time, Meayll Hill has become a habitat for several bird species listed on the Red and Amber List, these include gulls, kestrels, linnets, and meadow pipits. Environmental Concerns and cultural heritage - disrupting cherished landscapes and causing harm to local flora and fauna. Power from the turbines would only benefit Ballaman and would not be for any communal benefit via the national grid Previously this application has been made and rejected. I trust that the Planning Committee will, again, carefully consider the submissions. The environment, wildlife, and community's well- being should be paramount in all planning decisions and remain our top priority.
o 7 Cronk Y Thatcher, Colby - The turbines would have a detrimental visual impact on an area of outstanding natural beauty and would significantly impair a lovely landscape. The Meayll peninsula is a lovely area and should be protected against further development, particularly as it is not zoned for development. This application is contrary to many of the policy principles laid out in the Strategic Plan including the policies regarding development on unallocated sites, the protection of the open countryside, the harm it would do to the character and quality of landscape as well as the disruption that would be caused environmentally. There would be significant levels of both noise and light pollution. The turbines would also have a detrimental impact on both bird and wildlife in the area due to noise and turning blades.
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I cannot believe that the benefit of the very limited amount of power generated by two turbines could in any way outweigh the negative impacts that such an unneighbourly, unsightly and noisy could have on a beautiful and peaceful area enjoyed by many walkers, cyclists and visitors, including myself.
From further afield o The Hon. Juan Watterson BA(Hons) BFP FCA CMgr FCMI FRSA SHK Speaker of the House of Keys - Object. Please note my correspondence of 2014 and 2016 regarding similar applications at Ballaman. Having reviewed the planning application, I believe the points made then are every bit as applicable as they are now and I would appreciate these being taken into consideration in determining this application. I should point out that I would be more sensitive to this proposal if the turbines were feeding into the national grid creating communal benefit, rather than for one individual. However, I do not believe this is the case.
o 167 Clapham Road, London SW9 0PU - frequent visitor and a part time resident of Port St Mary
6.0 ASSESSMENT 6.1 The key issues are whether there are any adverse environmental impacts from the turbines and their operation on the visual character and appearance of the area, the local ecology, the living conditions of those in any dwellings in the area, the safety of the operation of the Island's principal Airport or any site of archaeological interest or importance and if so, whether the environmental benefits of harnessing renewable energy in this case, outweigh these concerns. These are dealt with in turn as follows:
o Environmental Impact Assessment (EIA) o Visual character o Ecology o Impact on the living conditions of those in any dwellings in the area o Impact on the safety of the operation of the Island's Principal Airport o Impact on any site of archaeological interest or importance o Whether the environmental benefits of harnessing renewable energy in this case, outweigh these concerns o Conclusion
Environmental Impact Assessment (EIA) 6.2 The question of whether a formal Environmental Impact Assessment (EIA) is required to inform the application is raised. Nowhere in the applicants submission has this prospect been covered.
6.3 Strategic Plan Environment Policy 24 indicates that EIA will be required in certain cases. Paragraph 7.18.2 of the main text of the SP clarifies that in some cases EIA will be required in every case (Paragraph A.5.2 of Appendix 5 sets out the cases) and in other cases will be required depending on the nature of the proposal/area (thus paragraph A.5.2 of Appendix 5 is akin to "Schedule 1" development in the UK). This indicates under Section (c) Energy Industry, (inter alia) that: o Installations for the harnessing of wind power for energy production require an EIA.
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6.4 However, an important distinction between the Isle of Man and UK is that in the Isle of Man, the requirement for EIA comes from policy rather than legislation. A proposal which is listed under A.5.2 and does not have an EIA would not be in accordance with Strategic Plan Environment Policy 24. Therefore, in theory, a planning application could be submitted without an EIA for a type of development listed in A.5.2 and still be validated/processed. A judgement on the validity of the application is, therefore, required.
6.5 In this case, if this were the UK, the proposed development would not constitute a schedule 2 development as defined by Regulation 2(1) (3)) as it is not on a site measuring more than 0.5 hectare, it does not have 2 or more turbines, and the wind turbines do not have a hub height of 15 or more metres.
6.6 In making a judgement, which is allowable in the Manx Planning System and current legislation, the proposed development is not considered to be formal EIA development due to its limited size. Overall, the easternmost part of field 414697 is estimated to constitute 7,000m2; the estimated land required for wind turbine foundations is 13.52m2 based on two 6.76m2 foundation pads, or 0.19% of the total area. If the land required for the approved solar panels is also included (754.82m2), then the combined land required to deliver the approved solar panels and wind turbines will be 10.97% of the total area. This is less than the 0.5ha threshold for Schedule 2 EIA development in the UK. The small area of the site, the relatively small-scale (2 No. wind turbines of 9.0m hub height and a max. 11.8m high to the turbines blade tip), represents a small-scale development. Furthermore, the applicant has submitted a considerable amount of information that would be required as part of any EIA in order to inform the application, and this is judged to be of an acceptable standard. Therefore, a formal EIA is not required for the application to be considered and determined as submitted.
Visual character 6.7 The site forms part of a field located to the west of Ballnahowe Road, (also known as Darragh) and to the south of the entrance drive to Ballaman. The land holding at Ballaman extends to the west to a headland which overlook a populated bay at Port Erin which provides a range of facilities for residents and visitors alike. It is screened from the roadside by the existing entrance walls to the drive serving Ballaman and by the roadside gorse hedge and Manx sod bank boundary. The road is set at a lower level to the site. The site also, forms a relatively shallow sloping plateau in this location, and is screened by mature hedging along its southern boundary. In terms of wider views, the site is also looked down upon from public footpaths and an Ancient Monument, Meayll Circle. In addition, the site is not completely visible from the public footpath which skirts the coast, linking Port Erin with The Sound. The site can, therefore, be seen from a number of public and private vantage points, with the impact of the proposal differing depending upon the position and level of the viewpoint and its distance from the site. It is also subject to distant views being capable of observation from the northern side of Port Erin Bay at south Bradda and Bradda Head.
6.8 There is correspondence from residents of Port Erin, Port St. Mary as well as from as farther afield in Douglas, Onchan and Santon on the Island, as well as off-Island. These viewpoints are at a considerable distance - 1.3km to Bradda, 2.3km to Surby and around 1km to the lower part of the upper promenade. Whilst the higher part of the Promenade, Bradda and Spaldrick all have views in this direction, it is not considered that the distance enables such a clear view of the proposed turbines that they would be so discernible as to warrant a visual impact so significant as to warrant refusal for reasons relating to the outlook from these properties. The impact on a private view is not a material planning consideration. It is of course the case that there are also public views from Spaldrick, Bradda and the higher part of the promenade but again, the distance from these vantage points is considered to be such that a clear view would not be available which would so adversely affect the general landscape sufficient to refuse the application. This is confirmed by the 16 viewpoints submitted with the application produced using LIDAR (Light Detection and Ranging) DSM (Digital Surface Model) Terrain data from the
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IoM Infrastructure Dept. which in effect represent a Landscape Visual Impact Assessment (LVIA).
6.9 The viewpoints are listed as follows: Viewpoint 1 - Milners Tower - located at Bradda Head - Very distant view of the wind turbines - nearest turbine is 1648m Viewpoint 2 - Tower Road - on N side of Port Erin bay - Very distant view of the wind turbines - nearest turbine is 1609m Viewpoint 3 - Bradda East - Very distant view of tops (rotors) of wind turbines - nearest turbine is 1917m Viewpoint 4 - Shore Road, port Erin - Wind turbines not visible - nearest turbine is 751m Viewpoint 4b - Shore Road North - Distant view of tops (rotors) of wind turbines - nearest turbine is 954m Viewpoint 6 - The Castles - Wind turbines not visible - nearest turbine is 455m Viewpoint 7 - Darrag - Wind turbines not visible - nearest turbine is 751m Viewpoint 7b - Breagle Glen - Distant view of tops (rotors) of wind turbines - nearest turbine is 584m Viewpoint 8 - St Mary's Road - Distant view of tops (rotors) of wind turbines - nearest turbine is 659m Viewpoint 9 - Port Erin Bay - Medium distance view of wind turbines - nearest turbine is 394m Viewpoint 10 - Truggan Road - Distant view of tops (rotors) of wind turbines - nearest turbine is 823m Viewpoint 11 - Mull Road - Close view of upper part of wind turbines including rotors - nearest turbine is 112m Viewpoint 12 - Bay Fine - Wind turbines not visible - nearest turbine is 804m Viewpoint 12b - Near Bay Fine - Distant view of tops (rotors) of wind turbines - nearest turbine is 569m Viewpoint 13 - The Howe - Distant view of tops (rotors) of wind turbines - nearest turbine is 1247m Viewpoint 14 - Meayll Circle - Distant view of wind turbines - nearest turbine is 581m Viewpoint 15 - Mull Road Southbound - Closer distance view of wind turbines - nearest turbine is 260m Viewpoint 16 - Track Near Ballahowe - Closer view of wind turbines - nearest turbine is 202m
6.10 Within Port Erin, as the promenade descends, the view of the turbines will become closer but towards the lowest point, the topography of the site will prevent a view of them. There is also a view of the turbines which is available from the sea when viewed from within the bay although the site is one small part of a much wider landscape and with much of that view having a backdrop of the surrounding hillside. From few places to the north and north-west will the turbines be visible on the skyline. It is also relevant that there is already a line of overhead power cables which ascend the same hillside.
6.11 As one ascends Balnahowe Road, the turbines will be screened by the distance from the road and the high roadside hedges as well as the existing buildings at Ballaman. The turbines will start to become visible with a backdrop of the sea and sky as one proceeds higher up Balnahowe Road. As one reaches the brow of the hill, the turbines will be visible but in a wider panorama and one will look down on them with Ballaman and its entourage sitting alongside. From the Mull Circle, the turbines will be clearly visible within an impressive panorama of Port Erin, Milner's Tower and Bradda Head right around to Port St. Mary. Unlike the previous application for three turbines (PA 14/00632/B in Field 414526 closer to the sea) any view from the coastal footpath would be minimal.
6.12 Simply being able to see something does not necessarily make it objectionable. It is the impact on the character and appearance of that landscape which is the critical assessment and the Landscape Character Assessment 2008, and the submitted viewpoints are helpful in this respect. The Landscape Character Assessment 2008 identifies the character of the area as
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being the dramatic views of rising uplands to the north and across Port St. Mary Bay to the northeast, the dramatic views across the Sound to the Calf of Man, the panoramic, open views across the Peninsula and extensive, panoramic, open views across ever-changing sea and sky engulfing the character area on three sides and the overall strategy being to conserve the strong sense of openness of this rugged area, its expansive and dramatic views and to conserve the setting of the numerous archaeological features and Cregneash village and the surrounding traditional field pattern as well as the wartime structures on Meayll Hill. Most importantly, this has translated into Landscape Proposal 10 which states: "Any additional new built development on the Meayll Peninsula, other than very limited development near its northern edge at the former Marine Biological Station, should be avoided as such development would adversely affect the largely unspoilt character and appearance of the Peninsula and/or would diminish its role in providing a vegetated, undeveloped backdrop to Port Erin, Port St Mary and Cregneash." Furthermore, Landscape Proposal 11 states: "Should the opportunity arise, the radio beacon on Cronk ny Arrey and other communications apparatus on the Meayll Peninsula should be removed or, if necessary, replaced by more modest and less intrusive structures."
6.13 It is very difficult to reconcile a proposal for two new vertical, moving structures with these policies within such a landscape and particularly where other apparatus is recommended for being removed (albeit at a considerably larger scale than the current proposal) particularly when considering the view from Mull Circle. Whilst the applicant has considered other sites within his land holding such as that of the previously refused PA 14/00632/B proposal for three wind turbines of a similar size and scale, it is likely to be inevitable that such structures will be considered to have an adverse visual impact which it is considered in this case, that they will.
Ecology 6.14 The Ecosystems Policy Officer and others have raised concerns regarding the impact of the turbines on wildlife, particularly birds and most specifically red billed choughs which are protected under the Wildlife Act. In considering the previous application it is noted that the Manx Chough Project was in operation in 2014, and which at that time had identified 2 breeding pairs of Manx Choughs being seen on several occasions within the vicinity of the site. The risk to birds from turbines is generally twofold - they can be killed or injured through coming into contact with the blades and they can also be prompted to relocate due to the turbines deterring them from visiting the area which may be used for foraging or in some cases (but not believed to be this one) breeding. The availability of good quality foraging areas in the vicinity results in the concern about relocation of the species. There remains a concern about bird strike. The applicant's additional Preliminary Ecological Appraisal by Atmos Consulting attempts to address this and following discussions with the Ecosystems Policy Team, resulting in the re-siting of the 2 turbines away from boundary hedges, this objection has been withdrawn. It is relevant that DEFA's Ecosystems Policy Officer does not object to the application on these grounds although did raise caution regarding the impact on bats and recommended that this further distance between the turbines and any hedging would assist in minimising the impact on bats.
6.15 The absence of any firm objection from a qualified authority on ecology provides less scope for an objection on these grounds, and in particular, Manx National Heritage in their latest communication note: " This ecological mitigation report proposes a small number of strategies that will deter red billed choughs from the immediate area surrounding the turbines which we would like to see incorporated into any future approval". MNH concludes its comments by advising: "Whilst MNH support the principle of renewable energy we would like to see further information requested above, regarding avian and bat migration routes, in order to be able to make an informed decision about this application. We very much urge the applicant to contact the relevant organisation on the Island such as Manx Bat Group and Manx Bird Life before proceeding with this proposal."
Impact on the living conditions of those in any dwellings in the area
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6.16 The closest property to the turbines is Ballaman itself, the applicant's own property. Those further from the site are some distance away - approx. 200m and as such, it is not considered that the turbines would have such an impact on local residents as to warrant refusal for reasons relating to impact on their living conditions. The turbines are small - 9 metres hub height, and 11.8 metres maximum height to the rotor tip. Noise impacts would be minimal, and shadow flicker from such a small installation is unlikely to occur. In terms of impacts on residential amenities no-one else who has written objecting to the application would be directly affected. In this regard, the proposal accords with Policy GEN 2 (g) ENV22 iii) and ENV 23 in the Strategic Plan.
Impact on the safety of the operation of the Island's Principal Airport 6.17 The Isle of Man Airport Operations Manager at Ronaldsway has indicated that there is no risk of the turbines interfering with the operation of the Airport, advising: "We have been working in conjunction with the developer. We have undertaken a physical safeguarding assessment and are satisfied that the current proposal does not penetrate any of our protected surfaces". The Airport manager has, however, requested that they would, require a specialist technical safeguarding assessment undertaken at the cost of the applicant to prove that the proposal has no effect on our navigational aids as a condition of any planning consent. This can be conditioned. As such, it is considered that the proposal accords with the provisions of Policy T10 of the Strategic Plan.
Impact on any site of archaeological interest or importance 6.18 The Mull Circle is not itself affected by the turbines and as such the setting of the monument and the provisions of Strategic Plan EP 40 cannot be said to be compromised as a result. Whilst the enjoyment of this site of archaeological importance would involve the turbines being directly visible when viewing the wider landscape panorama from Bradda Head to Port St. Mary, this is a concern in respect of the impact of the turbines on the character and appearance of the area rather than an impact on the monument itself.
Whether the environmental benefits of harnessing renewable energy in this case, outweigh these concerns 6.19 Renewable energy developments are generally encouraged as the Department and Government in general are committed to the steps as outlined in the approved Climate Challenge Mitigation Strategy 2020-2020 adopted June 2016 (GD 2016/0031). This outlined measures to be taken towards the 2050 target to reduce greenhouse gas emissions by 80% compared to 1990 levels. Government is now consulting on the options for inclusion in a new climate change mitigation strategy for 2020-2030 and interim targets. The approved Climate Challenge Mitigation Strategy 2020-2020 requires the Island to reduce greenhouse gas emissions, deep electrification of the energy system and promoting the use of sustainably sourced biomass and improvements to some land use practices. In particular that total greenhouse gas emissions from electricity generated on the Island will be close to zero by 2050. This will clearly necessitate the introduction of renewable energy harnessing developments as well as reducing total energy consumed and improving energy efficiency. The document includes specific references to wind power, amongst other renewables, acknowledging that the intermittent nature of some renewable energy resources, such as solar radiation, wind and wave generation, has led to questions regarding the viability of harnessing them as means of generating electricity. Fortunately, a range of options, from domestic to industrial scale, for storing electricity are already commercially available and this technology continues to evolve rapidly.
6.20 The approach by the planning authority to balancing the impact of the benefits of renewable energy against any environmental impact have varied, depending upon the nature of the impact. For example, a number of turbines have been approved - PA 14/00117/B for two turbines the same height as those now being proposed at Bay View Farm. These are now in situ and at Bride (PA 16/00033/B) and is the same height as that now proposed. A more recent application for a turbine of the same height as is now proposed, was at Ballacallin Farm in
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Gordon on the west coast of the Island, although this was refused for reasons relating to both visual impact and a lack of information on ecological impact (16/00902/B). This application was subsequently dismissed at appeal.
6.21 In this case, there is more independent information available to assess the acceptability of the visual impact of the development. This is provided in the Landscape Visual Impact Assessment submitted with the application as discussed in paragraph 6.4 above. In terms of the Area Plan and Landscape Character policies and proposals and it is clear that the overriding characteristic of the area is its openness and the quality of its views across to the sea at Port Erin, Port St. Mary and around the Sound. It is also clear that it is a long term policy objective of the Landscape Character Appraisal as outlined in Landscape Proposal 10 which states: "Any additional new built development on the Meayll Peninsula, other than very limited development near its northern edge at the former Marine Biological Station, should be avoided as such development would adversely affect the largely unspoilt character and appearance of the Peninsula and/or would diminish its role in providing a vegetated, undeveloped backdrop to Port Erin, Port St Mary and Cregneash."
6.22 As stated before, it is difficult to reconcile this objective with a proposal which will introduce a moving, vertical development into this landscape although it is accepted that from many viewpoints, the turbines will not create an unacceptable visual impact, or in fact will be barely discernible in the wider landscape. However, the adverse visual impact of the development compared to that refused/dismissed on appeal PA 14/00632/B proposal for three wind turbines of a similar size and scale, when viewed from the coastal footpath, has now been addressed with this particular site, and the 2 No. Turbines would be hardly visible from views from the coastal footpath. Views downwards from the Mull Circle, whilst obtainable, are not considered to be unacceptable because they would only relate to views from the Circle and whilst visible from the Circle, would not impact on the character of the Circle itself. It is considered that any identified harm is outweighed by the acknowledged benefit to the environment of the harnessing of renewable energy in general in line with Government objectives. Whilst there are other ways of harnessing environmental energy which would not have such visual impacts - for example solar energy which generally involves fixed equipment in the form of Solar Panel arrays, which the applicant has received approval for (See PA 22/00397/B - Installation of ground mounted solar array at Ballaman - site to south of Ballaman House - permitted - 7/9/22. This site lies adjacent, to the west and north of the current 23/00750/B application site for 2 No. Wind Turbines, and the two developments would form part of an overall renewable energy scheme to serve Ballaman. Whilst the energy generated by the scheme would only benefit Ballaman, it would mean a reduction in what Ballaman and its attendant facilities and structures currently draws from the grid, which is considered to be beneficial in the islands drive towards achieving net zero.
6.23 The application is recommended for approval on the grounds as outlined above. It is considered that the visual impact would not be so harmful when viewed from the higher perspective at the Mull Circle as to be outweighed by the environmental benefits of the scheme and would therefore be contrary to Environment Policies 1 and 2 and General Policy 3 all of the Strategic Plan and Landscape Proposal 10 of the Area Plan for the South. Any issues relating to Airport Safety can be resolved by the imposition of a planning condition; and, the impact of the proposals on Protected Species (Manx Choughs) other birds and Bats have been considered and mitigated for in the revised siting of the turbines away from the sites boundary hedges, which has met with the withdrawal of the Biodiversity Teams initial objection. In this regard, it is considered that this proposal overcomes the previous reasons for refusal attaching to the previous PA 14/00632/B application.
Conclusion 6.24 Strategic planning policies together with other government policies and strategies provide a positive framework for encouraging renewable energy developments, where appropriate. It is considered that the proposed 2 No. wind turbines would occupy a small portion of an open
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landscape and views of the turbines would be limited due to the topography in the area, the scale of development and existing vegetation.
6.25 It is considered that the environmental benefits of the proposed scheme outweigh the limited identified harm to the countryside and as such the proposed 2 No. wind turbines would comply with the Energy Policy 4 and Environment Policy 2. In addition the proposed wind turbines are not considered to unduly harm the residential amenity of the occupants of the nearby dwellings.
7.0 RECOMMENDATION 7.1 For these reasons set out above the proposal would be appropriate in this location and therefore the recommendation is for an approval.
8.0 INTERESTED PERSON STATUS 8.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons: (a) the applicant (including an agent acting on their behalf); (b) any Government Department that has made written representations that the Department considers material; (c) the Highways Division of the Department of Infrastructure; (d) Manx National Heritage where it has made written representations that the Department considers material; (e) Manx Utilities where it has made written representations that the Department considers material; (f) the local authority in whose district the land the subject of the application is situated; and (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material.
8.2 The decision maker must determine: o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and o whether there are other persons to those listed above who should be given Interested Person Status.
8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status. __
I can confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to the it 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.
Decision Made : Refused
Committee Meeting Date: 18.06.2024
Signed : Hamish Laird Presenting Officer
Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report).
Signatory to delete as appropriate YES/NO See below
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Customer note
This copy of the officer report reflects the content of the file copy and has been produced in this form for the benefit of our online services/ customers and archive records.
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PLANNING COMMITTEE DECISION 18.06.2024
Application No 23/00750/B Applicant Mr Adam Cooke Proposal Erection of two wind turbines Site Address Field No. 414697 Ballaman Ballnahowe Road Port Erin IM9 6JF
Planning Officer Hamish Laird Presenting Officer As above
Addendum to the Officer Report
The Case Officer emailed the members 5/6/24 17:34, with an addendum to his report and recommendation as published:
Isle of Man Government - DEFA - Planning Committee Meeting, Murray House, Mount Havelock, Douglas on Monday 10th June, 2024.
Addendum to Agenda Item No. 5.1
23/00750/B - Erection of two wind turbines on land at Field No. 414697, Ballaman, Ballnahowe Road, Port Erin, IM9 6JF
Revised Paragraph 4.2 of Planning Committee Report. This is an extract from the Isle of Man Landscaper Character Assessment - Final Report - dated July 2008.
4.2 Under the Landscape Character Assessment the site falls within H4 Cregneash Head and Meayll Peninsula, the overall character area description of which is as follows: "The Meayll Peninsula is situated at the south-western tip of the Island, and overlooks the Calf of Man. Landform rises from Port Erin and Port St. Mary to the north, towards the coastline to the south, where rugged dark cliffs rise from the dramatic sea below. A series of rugged bays line the coast and, in several places, rugged rocky outcrops extend into the sea. At the southernmost point, the distinctive rocky cliffs of Spanish Head form the boundary between land and sea, whilst further to the east (at the eastern head of Bay Stacka) the rocky landmark of Sugar Loaf stack provides a strong sense of place. Land use within the area varies, with patches of rough grassland and heathland in higher areas and in close proximity to the coast; and a patchwork of regular (often sheep-grazed) fields. Field boundaries are delineated by characteristic traditional stone walls, which denote a relatively regular field pattern. In places,
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low Manx hedges and patches of scrub also demarcate fields. Settlement pattern consists of a series of isolated, scattered farmsteads, which are peppered throughout the area. The area is served by Cregneash Road/Sound Road, which provides access to the southernmost point of the Island. From this, two minor, rural roads branch north and south, providing access to Port Erin to the north and Cregneash Automatic Wireless Transmitting Direction-Finding Station to the south. The distinctive traditional small village of Cregneash (now a folk museum) sits at the centre of the peninsula. This is the oldest village in the Isle of Man and encompasses an atmospheric arrangement of 19th century traditional crofter's cottages. At the southern end of Sound Road, the Sound Café (a traditional stone buildings with modern glass panoramic window and green roof) facilitates views across the Sound, towards the Calf of Man. From this point, dramatic views across the Sound to the Calf of Man, often with seals basking on Kitterland rocky outcrop in the foreground, can be gained. There is a strong sense of isolation and tranquillity, with chanting flocks of sea birds and the background crash of waves contributing to character and recognisable sense of place. A landmark white cross marks a memorial to loss of life as a result of shipwrecks within the Sound. Across the area, a sense of tranquillity and openness is strong, with panoramic views across peninsula and the surrounding ever-changing seascape. Dramatic views of rising uplands to the north and across Port St. Mary Bay to the northeast can be gained from the highest points. To the south of Cregneash, communication mast provides a dominant vertical element within views across the area."
Key views include: o Panoramic, open views across the peninsula. o Extensive, panoramic, open views across ever-changing sea and sky engulfing the character area on three sides. Among its notable historic features is: Meayll Circle (Meayll - in Manx meaning Bald or Bare Hill dates back to the late Neolithic or early Bronze Age). Used primarily as a prehistoric burial place, it is unique in archaeological terms combining the circle form with six pairs of cists (stone coffins) each pair having passage between which radiates outwards.
Landscape Strategy The overall strategy should be to conserve the strong sense of openness of this rugged area, its expansive and dramatic views and to conserve the setting of the numerous archaeological features including Cregneash village and the surrounding traditional field pattern."
Revised by Hamish Laird - Case Officer - 5/6/24.
At the Committee Meeting on 10/6/24, Members voted 5-2 to reject the Officer recommendation and voted 2 - 5 to Refuse the application for the following reasons:
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wind turbines would run counter to this long-standing advice and as such is contrary to it, and the provisions of Strategic Objective 3.3b); Strategic Policy 4b); General Policy 2 c); and, Environment Policies 1 and 2 contained in the Isle of Man Strategic plan 2016.
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