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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 21/01311/B Applicant : Department of Home Affairs Proposal : Installation of ground mounted solar array. Site Address : Area Of Land Adjacent To Upper Howe Farm Old Castletown Road Douglas Isle Of Man
Planning Officer: Mr Paul Visigah Photo Taken : Site Visit : Expected Decision Level : Planning Committee
Recommendation
Recommended Decision:
Permitted Date of Recommendation: 11.02.2022 __
Conditions and Notes for Approval
C : Conditions for approval N : Notes attached to conditions
C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
C 2. In the event that the panels hereby approved are no longer in use, they shall be removed from the site within 6 months of their last use.
Reason: In the interests of visual impact and protection of the countryside.
C 3. Prior to the commencement of the development hereby approved details shall be provided to the department including:
Reason: the site has been identified as being of sufficient value to be a Local Wildlife Site, the assessment of the site identifies gorse as being a particular concern the proposed development will not require the complete clearance of the site and so some habitat within the site can be retained and enhanced in accordance with Strategic Plan Environment Policies 4 and 5.
This application has been recommended for approval for the following reason. Overall, it is concluded that the planning application is in accordance with Environment Policy 22 and Energy Policy 4 of the Isle of Man Strategic Plan 2016, as well as wider Government climate change strategy, having no adverse impacts on private or public amenities.
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Plans/Drawings/Information; This approval relates to the following documents: o Site Photographs, o Location Plan, o Solar Panel Details, and o Drawing No. 03 (Proposed Site Layout & Typical Section through Solar Dig Out Area),
All received 3 November 2021. __
Interested Person Status - Additional Persons
None __
Officer’s Report
THIS APPLICATION IS REFERRED TO THE COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT.
1.0 THE SITE 1.1 The application site is an area of land adjacent the DHA Tower and buildings which is situated about 143m northwest of Upper Howe Farm, Old Castletown Road, Douglas. The site slopes southwest wards towards the coastline. The site is covered in low level vegetation which rises to approximately 500mm on most parts of the site and surrounding area which undulates as it slopes southwards.
1.2 The site is visible from a number of public locations but from each of these at a fairly significant distance. The closest views of the site are achievable from the nearby Upper Howe Farm, to the southeast, but this as well as the entirety of the access track to the site (from Castletown Road) are within private ownership. Other distant public views can be found along the Old Castletown Road in the area of Quine's Hill and in and around the area of Kewaigue Hill/Cooil Road roundabout (A5/A6).
1.3 Aside from the towers, the building associated with the DHA tower and the two satellite dishes are the most visible of the associated structures in the area. The associated buildings structures tend to be read against the low level vegetation that is found on the edges of the site.
1.4 The weather can also have a considerable difference in what can and can't be seen from the views outlined.
2.0 THE PROPOSAL 2.1 The application seeks planning approval for the Installation of ground mounted solar array. The scheme would involve the installation of a total of 40 x 340Watt Panels (1650mm x 990mm), mounted into Renusol ConSole ballast system fixed to the ground. The solar would be split into four separate rows/blocks which when laid out would cover an area 18.4m x 8.4m. The solar panels will be angled at about 26 degrees on the support units and on frames. The highest part of the support base would be 0.5m above the ground level.
2.2 The proposed scheme would generate 13.68 KW of electricity and be situated to the North East of the Carnane Communications mast. Array strings will be laid on a hardcore base and removal of top vegetation will be kept to a minimum. Any organic material will be left on site to decompose naturally.
3.0 PLANNING POLICY
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3.1 The site is located within an area zoned as 'Telecommunications Sites (Carnane & Crookall House TETRA sites)' on the Area Plan for the East (Map 4- Douglas), and the site is not within a Conservation Area. The site is not at risk from flooding nor are there any Registered trees on the site. The site is also not within a Registered Tree Area. As such, the following parts of the Strategic Plan are relevant:
3.2 The Character Appraisal within the Area Plan for the East states thus concerning the area: "Landscape Character Area: Douglas Head (D12)
3.2.1 Landscape Strategy Conserve and enhance: a) the character, quality and distinctiveness of the area, with its open and panoramic views over large rectilinear fields; b) its steep winding small lanes enclosed by grassed Manx hedges; c) its scattered hill farms fringed by trees.
3.2.2 Key Views Open and expansive views from most of the area out to sea, along the coast, over Douglas Bay and inland over the incised inland plateau up to the northern Uplands. Telecommunications tower on hill top forms highly visible landmark in surrounding areas.
3.3 The following parts of the Area Plan Written Statement are also considered relevant:
3.3.1 Paragraph 7.10.2: "The transmitter site on the top of Carnane plays a vital role in the delivery of the wireless network. It is important that proposals do not compromise the developability of the site and providers have the confidence to invest in the network and deliver the goals set out in National Telecommunications Strategy".
3.3.2 Utilities Proposal 1 (Serviceability): a) All development must be connected to the appropriate service and utility. b) In order to achieve this, each service and utility required must be capable of receiving a new connection and sustaining it".
3.3.3 Utilities Proposal 3 - Electricity, Telecommunications and Gas which shall be taken to represent a policy statement on Utilities in the East (In part): o "The electricity supply system must be designed in accordance with the requirements of the relevant electricity supply agency and be provided to all premises. o Arrangements that support the generation or use of renewable energy at site level or neighbourhood level are encouraged".
3.3.4 Landscape Proposal 6 (Douglas Head) Douglas Headland states it, "is exposed and prominent from many viewpoints. This is considered an outstanding natural feature and one which should be conserved. In order to conserve this vista of seascape and coastal views, applications for planning approval for new development in this area will generally not be supported. It is acknowledged that maintenance and need for upkeep may lead some existing development to seek planning approval from time to time, such as the radio transmission/telecoms site at Carnane. In cases where new development is proposed, applications must demonstrate that it can be suitably integrated into the surrounding landscape setting through reasonable mitigation measures and include considering siting, colours, materials, finishes and the general scale".
3.4 In the assessment of 19/00129/B it was identified that the site is within a designated Wildlife Site. This is not a statutory designation, but is a site assessed for its value and given protection by the Manx Wildlife Trust, who were responsible for the designation in the first
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place on the basis of a clear understanding of the value of the site. This designation has not been reflected on the Area Plan for the East constraints map however, given the planning history of the site, the MWT were contacted to clarify whether the site was a Local Wildlife Site. Details of the site citation were provided by MWT (09.09.21). CABO were contacted to confirm why the site was not included in the Area Plan, and they responded (10.09.21) and noted that the MWT did not flag the site up to them as part of the area plan process but the omission from the plan should not prevent their consideration as part of planning applications.
3.5 Due to the site location, zoning and the type of proposal, the following policies are relevant for consideration:
3.5.1 General Policy 2 states: "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:
(b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them; (c) does not affect adversely the character of the surrounding landscape or townscape; (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks; (g) does not affect adversely the amenity of local residents or the character of the locality; (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space; (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; (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and
3.5.2 Paragraph 12.2.8 of the Isle of Man Strategic Plan 2016 states, "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. Energy efficiency and the use of renewable energy sources are covered in General Policy 2(m) of the Building Regulations. At the same time the Department recognizes that renewable energy sources can have adverse environmental impacts. The idea of a wind turbine Installation is currently being investigated and considered by the Manx Electricity Authority. Any feasible site is likely to be exposed and have considerable visual impact. There may also be other impacts such as noise. On a smaller scale, the popularity of domestic wind turbines has been increasing in recent years in response to rising energy prices and increasing awareness of climate change. Planning applications for domestic wind turbines are unlikely to require the submission of an Environmental Impact Assessment. The Department will assess any proposals for wind turbine installations by weighing the benefits of using such renewable energy sources against the environmental impact arising in any particular site. It is likely that the visual impact would be less detrimental on a coastal site than on a rural or upland one. Accordingly:
3.5.3 Environment Policy 22 of the Isle of Man Strategic Plan 2016 states: "Development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties in terms of: i) pollution of sea, surface water or groundwater; ii) emissions of airborne pollutants; and iii) vibration, odour, noise or light pollution."
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3.5.4 Energy Policy 4 of the Isle of Man Strategic Plan 2016 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 submission of an EIA".
3.5.5 Appendix 5 of the Strategic Plan identifies developments where an EIA is required. It states in part: (c) Energy industry i. Thermal power stations and other thermal installations ii. Surface storage of natural gas iii. Underground storage of combustible gases iv. Surface storage of fossil fuels v. Industrial briquetting of coal and lignite vi. Installations for the harnessing of wind power for energy production
3.5.6 There is no reference made to the installation of solar panels within appendix 5. The scale is also not considered to be significant enough to warrant an EIA in any case, and the site is not a sensitive site as stated in paragraph 3.1 of this report.
3.5.7 Strategic Policy 1 states: "Development should make the best use of resources by: (a) optimising the use of previously developed land, redundant buildings, unused and under-used land and buildings, and re-using scarce indigenous building materials; (b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space(1) and amenity standards; and (c) being located so as to utilise existing and planned infrastructure, facilities and services."
3.6 The Isle of Man Strategic Plan 2016 also contains the following policies that are considered specifically material to the assessment of this current planning application.
3.6.1 Other policies within the Strategic Plan which are considered relevant in the assessment of the proposal are; Infrastructure Policy 5, Community Policy 11, Community Policy 7, Community Policy 10, and Environment Policies 4 and 5 (which seeks Biodiversity Protection).
4.0 OTHER MATERIAL CONSIDERATIONS 4.1 Isle Of Man Future Energy Scenarios (2020): 4.1.1 In December 2020, the Isle of Man Government launched its Future Energy Scenarios Strategy to determine the pathways to meet the following: 4.1.2 Key Targets: o To ensure 75% of the island's electricity is generated from renewable sources by 2035 and to deliver net zero emissions by 2050.
5.0 PLANNING HISTORY 5.1 The current site of the proposed scheme itself has not been the subject of any previous application, though clearly the eastern section of the site has been subject to the following planning applications:
5.2 PA 16/00266/B for Erection of four satellite ground antennas with related buildings and security fencing - APPROVED
5.3 PA 17/00082/B for Erection of four satellite ground antennas with related buildings and security fencing (comprising amendments to PA 16/00266/B) - APPROVED
5.4 PA 19/00010/B for Extension of existing site including the erection of additional telecommunications equipment, erection of small office and welfare facility for maintenance staff, all with associated ground works, landscaping, fencing and video surveillance poles -
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APPROVED. This application addressed matters of ecology for the broader site area which is considered relevant to the current scheme.
5.5 The additional two adjacent sites have both been the subject of a number of applications over several decades for various telecommunications and other related equipment, with the most recent coming in 2008. None of these, though, is considered to be directly material to the assessment of the current proposal for satellite antennae.
5.6 The current scheme is expected to provide sustainable energy source for the above facilities which have been erected within the broader site area.
6.0 REPRESENTATIONS Copies of representations received can be viewed on the government's website. This report contains summaries only.
6.1 Representation from the Department of Infrastructure (DOI) Highways Division confirms that they 'Do not oppose' in a letter dated 13 December 2021.
6.2 Braddan Commissioners have stated that they have no objection to the application in a letter dated 19 November 2021.
6.3 No comments have been received from the neighbouring properties.
7.0 ASSESSMENT 7.1 In assessing the acceptability of the principle of the proposed development, it is considered that the site is within an area zoned for development, particular telecommunications uses and the proposed use would be broadly in keeping with the setting of the area, and its established use. As well, the installation of the solar panels at the site will accord with the general support given to the introduction of renewable and alternative energy sources as set out in the Strategic Plan, and is not required to provide an EIA.
7.2 Also relevant is the fact that there is established support for such schemes within the Area Plan for the East, particularly for utility sites such as the application site as has been articulated in Utilities Proposal 3 which weighs in favour of arrangements that support the generation or use of renewable energy at site level. Their introduction here is expected to help contribute to the overall operation and energy efficiency of the transmitter site on the top of Carnane which is considered to play a vital role in the delivery of the wireless network, and as such considered to be of strategic importance to the Island. In this respect the proposal is considered to comply with paragraph 12.2.8 and Energy Policy 4 of the Strategic Plan.
7.3 Equally, regard must be given to the reasonableness of the scale and siting of the proposed developments in view of their subsequent impacts, if any, on the surrounding area taking into account the existing built form that exists on site and vicinity. In this case, it is relevant to consider that the solar panels would be installed within an open part of the site and within close proximity to the existing infrastructure on site, while also having the most solar gain.
7.4 From public views, the solar panels would not be apparent, given the trees which run along large sections of the Old Castletown Road, the elevated nature of the site area which offers limited views to the site area (with the masts being the most apparent features from distant views attainable), and the shrubbery on large sections of the site. Additional information has also been provided by the applicants which provides details of the type of solar panels to be installed, their appearance, with photographs to show how they would appear in elevated positions. As such, the position of the solar panels on this open part of the site (which is surrounded by low shrubbery) would not spoil the character of the site and surrounding
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area. As such, it is considered that the scheme would comply with General Policy 2 (b, c, e, & f), and Strategic Policy 1.
7.5 In assessing the road safety impacts, a key concern associated with solar panels is the possibility of the solar panels causing glare for divers using nearby highways. In the case of the current application, it is considered that that angle of inclination of the frames towards the coast, the elevation of the site which is well above the road level of Marine Drive (to which the panels are inclined towards), as well as the intervening structures and building situated southwest of the location for the solar panels, would ensure that there would be no detrimental impacts in terms of reflections from the solar panels. It is also vital to note that DOI Highways have reviewed the scheme and raise no objection to the proposal.
7.6 As has been established in paragraph 3.4 of this report, the application site is an important wildlife site (although this is not reflected in the Area Plan for the reasons articulated in 3.4 above), and as such it would be vital to consider the possible impacts of the scheme on the ecology of the area. In terms of the impact on the biodiversity of the site, PA 19/00010/B references a report which was previously commissioned (2016) from the Manx Wildlife Trust. The case officer report for PA 19/00010/B states the following regarding the stated report: "Paragraph 6.20 (In part): The report identifies the heathland habitat as being fairly limited in quality here, although the potential (in respect of invertebrates and reptiles) is quite high", in that case it was concluded that the overall impact was not sufficient to warrant refusal, and there was some discussion of management and mitigation.
7.7 Whilst the current site is not directly within the site for PA 19/00010/B, it directly abuts this site and within the broader site area to which the study refers. Besides, the scale of the current scheme is considerably small in comparison to that which was considered acceptable under the above application in terms of impact on ecology. As such, it is considered that any impacts on ecology would be minimal and not sufficient to warrant refusal of the scheme. The proposal would, therefore, comply with Environment Policies 4 and 5, subject to a condition relating to the removal of the panels from the site should they no longer be required, within 6 months of their last use and a condition requiring further details to be provided of how the remainder of the site would be managed to minimise/mitigate any impact.
8.0 CONCLUSION 8.1 For the above reasons, it is concluded that the development proposed is acceptable when assessed against the relevant policies and the site context. It is recommended that the planning application be approved.
9.0 INTERESTED PERSON STATUS 9.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:
(a) the applicant (including an agent acting on their behalf); (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.
9.2 The decision maker must determine:
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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 __
I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to that body by the appropriate DEFA Delegation and that in making this decision the Committee has agreed the recommendation in relation to who should be afforded Interested Person Status.
Decision Made : Permitted
Committee Meeting Date: 21.02.2022
Signed : P VISIGAH 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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