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PLANNING OFFICER REPORT AND RECOMMENDATION
Application No. : 22/01114/B Applicant : ASAP LTD Proposal : Demolition of existing three apartments on site and erection of six replacement dwellings Site Address : Sea Court Victoria Road Douglas Isle Of Man IM2 6AQ
Planning Officer: Mr Paul Visigah Photo Taken : 31.01.2023 Site Visit : 31.01.2023 Expected Decision Level : Officer Delegation
Recommendation
Recommended Decision:
Refused Date of Recommendation: 16.06.2023 __
Reasons for Refusal
R : Reasons for Refusal O : Notes attached to reasons
R 1. The proposed siting, layout, scale, and arrangement of the new buildings on the site, would fail to relate positively and appropriately to the site character as it does not take into account a proper analysis of site context in terms of siting, layout, scale, landscape features, and spaces between buildings, and would have a deleterious impact on the application site, by resulting in a particularly intrusive development within the site when viewed from the surrounding area. The proposal, therefore, conflicts with General Policy 2(b and f) of the Isle of Man Strategic Plan 2016, and Paragraphs 3.1.4 to 3.1.7 of the RDG 2021.
R 2. Due to the overall height, width, form and layout of the proposed development, the proposal would disrupt the general rhythm of the overall group of buildings, and result in an obtrusive built development within an area comprising mainly large houses within generous gardens associated with the dwellings. The development would also result in the removal of large areas of mature landscaping which contribute to the character of the locality and townscape, resulting in the decline of the landscape quality and nature conservation value of this urban area contrary to Strategic Policy 4(b), Environment Policy 42, and General Policy 2 (b, c and g), and the latter part of Strategic Policy 3(b) of the Strategic Plan.
R 3. The proposed second floor bedroom windows, by virtue of their proximity and height, would result in unacceptable levels of actual and perceived overlooking from the proposal site into 'West Hill', , to the detriment of the residential amenity. Likewise, the scheme, by virtue of its proximity, height which towers to three storeys, and overall mass, would have an adverse impacts upon the outlook of 'West Hill' resulting in an overbearing impacts, particularly as the existing mature landscaping which would serve to soften any overbearing impacts would be
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removed. In this respect, the proposed development is considered to be unacceptable when assessed against General Policy 2 (g) and the relevant sections of the Residential Design Guide.
R 4. The potential for the loss of biodiversity on site would adversely affect the site character, and would detrimentally affect the amenity value of the mature landscaping within the site. The proposal also has the potential to adversely impact on a variety of biodiversity such as feeding, sheltering and breeding birds, feeding and commuting bats, and invertebrates due to the loss of the mature garden habitats linked to an established wooded area which houses protected species, and there is insufficient information to clearly ascertain the resulting impacts on ecology or that the appropriate mitigation has been provided for ecological loss. Therefore, the proposal is contrary to General Policy 2 (d), Strategic Policy 4(b), Paragraph 7.8.6, and Environment Policy 4 of the Strategic Plan (2016), and the IOM Biodiversity Strategy 2015 to 2025.
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Interested Person Status - Additional Persons
It is recommended that the following Government Departments should not be given Interested Person Status on the basis that although they have made written submissions these do not relate to planning considerations:
Manx Utilities Authority Drainage
It is recommended that the owners/occupiers of the following properties should be given Interested Person Status as they are considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
West Hill, Victoria Road, Douglas, as they satisfy all of the requirements of paragraph 2 of the Department's Operational Policy on Interested Person Status. __
Officer’s Report
1.0 SITE 1.1 The application site is the residential curtilage of Sea Court, Victoria Road, Douglas, a two storey property, situated within in its own large curtilage of mature gardens. The property which is comprises three apartments, and which bears the semblance of a detached dwelling is enclosed on its entire boundary by mature landscaping comprising trees and shrubbery.
1.2 The existing building on site is characterised by its prominent chimney stacks, its hipped roof finish, painted render external walls, and a mixture of Georgian arched window and casement windows, and three integral garages on its front elevation. From the highway the property is bounded with a Manx stone wall and mature planting above with bushes and trees effectively screening the property from the public highway. Access is from an existing gated driveway with pillars to each side and set back from the edge of the carriageway, with the boundary wall directly adjoining the highway and offering very limited visibility onto the highway.
1.3 The street scene of Victoria Road, particularly the western side of Victoria Road is characterised in terms of buildings and landscape character by large buildings laid out within large plots with mature landscaping. The northern end of Victoria Road where the property is situated is also characterised by mature trees and hedges along its roadside edge including
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small woodland groups which give a verdant nature to the streetscene. To the west of the site, sits the St Georges AFC club grounds which includes banks of mature trees along its southern boundary which links through to the trees on the application site and are of some visual prominence and importance in the streetscene.
1.4 Another key feature of the western part of Victoria Road is that all the dwellings/properties front onto the highway and there are no side-on or rear facing orientations, aside from Red House, Victoria Road which does not form a continuous group with the existing building group here and whose access is off a private lane shared with the Glenside Residential Home, Victoria Road.
2.0 PROPOSAL 2.1 The application seeks approval for Demolition of existing three apartments on site and erection of six replacement dwellings. The proposed scheme would seek to replace the existing building on site with six replacement dwellings comprising three semi-detached three storey house types, with two house type designs with varied internal layout and external designs. The two House type 1 semi-detached dwellings would have side-on orientation with side elevation facing the road, while the third (House Type 2) semi-detached building which would be set back further into the site would front onto the highway. All of the dwellings will have two off road parking spaces, while access to and from the site will be via Victoria Road.
2.2 The proposed dwellings would all have pitch roof over and integrate a combination of external wall finishes, although no details of roof material, window and door material or external wall finishes have been detailed within the submitted plans or Design and Access Statement.
2.3 The proposal would also include the following: a. The houses would have solar panels incorporated on the roof to assist with the heating and hot water load of each dwelling (No details of the power generation and type has been indicated).
b. A cycle storage rack which the applicant indicates would be provided to park and lock 12 bicycles is to be provided in front of the side on semi-detached building to the west, although no details of the type and design has been provided.
c. All the trees on site would be removed and replaced with new planting.
2.4 The applicants have provided additional documents in the form of: 2.4.1 Design and Access Statement: which provides details on the site characteristics; character of locality; Planning Policy framework open which proposal was formed; design basis; accessibility issues including vehicles/deliveries, refuse collection, public transport/pedestrian access, cycle provision; as well as Consultation carried out.
2.4.2 Arboricultural Impact Assessment Report prepared by Manx Roots Limited, and dated August 2022. The report is also accompanied by supporting tree plans. The following are extracts from the report:
"4.3. Impacts of the proposed development on retained trees 4.3.1. Due to the extent of the proposed development no trees within the site boundary will be retained. 4.3.2. The individual tree, T1, located outside of the site boundary, will have a minor RPA incursion (3%) on its northern side, but this is not expected to have a significant impact on the long-term health of the tree. It should be noted that because this tree is outside of the site boundary, the owner of the site has the right to cut back roots to the boundary. The intention, however, is to protect as much of the RPA as possible.
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4.3.3. The individual tree, T2, also located outside of the site, will not be affected by the proposed development if adequate protection measures are implemented 4.4. Impact of the retained trees on the proposed development 4.4.1. The retained trees are not expected to have any impact on the proposed development.
4.5. Visual impact 4.5.1. The visual impact of removing the trees 1378-1380, trees 1386-1389, and the group G1, will be moderately high as they can be seen by the passing traffic on Victoria Road. New planting is proposed between the car parking spaces and the road, however, which will help to mitigate this impact.
4.6. Loss of arboricultural value 4.6.1. The loss of arboricultural value associated with this development is not significant. The large category B eucalyptus tree is outgrowing the location and will likely need to be removed soon anyway. The smaller category B trees, 1380 and 1386, show good form for their age/species, but their removal can be easily mitigated within the site from new planting.
4.7. Recommended protection measures for retained trees 4.7.1. An Outline Tree Protection Plan (OTPP) is provided in the supporting drawing OTP- 160822. This drawing illustrates the extent of the Construction Exclusion Zone (CEZ) recommended around retained trees and landscaping areas. 4.7.2. The OTPP has been provided to show where protection measures could be implemented based on the proposed site layout and design. It does do not provide technical specifications for fencing, or for site supervision and monitoring, which would be necessary to provide a high level of confidence in the outcome for retained trees. If the planning application for the proposed development is approved it is recommended that an Arboricultural Method Statement (AMS), which describes the required protection measures and supervision processes in greater detail, is prepared prior to commencement. 4.7.3. It is recommended that a CEZ is implemented around T1 and T2, to protect the portions of their RPAs which cross the site boundary. It can also cover proposed tree planting areas on the western boundary to preserve the soil environment here and give newly planted trees the best chance of successfully establishing. Temporary protective fencing should be placed on the internal boundaries of these CEZs.
2.4.3 Road Safety Audit Stage 1 Report prepared by HMTC Highways Mann Transport Consultants and dated December 2022, and other supporting highway plans. This report provides details of five (5) highway problems that have been identified by the report which borders on risk of flooding, issues with sight lines, risk to pedestrians, risk of collisions due to lack of space and swept path information and risk of collisions due to lack of priority Give Way markings. The report also makes recommendations on how the problems could be resolved.
2.4.4 Road Safety Audit - Designers response document prepared by HMTC Highways Mann Transport Consultants and dated December 2022. This report seeks to address the concerns that have been identified by the Road Safety Audit Stage 1 Report and provides reference to design solutions to the problems.
2.4.5 Planning Statement Relating to Drainage prepared by BB Consulting and dated February 2023 has also been provided by the applicant. This statement states the following: "1. EXECTUTIVE SUMMARY 1.1. The MUA have confirmed that there is adequate capacity within the existing downstream, public combined drainage system to receive the proposed attenuated, surface water flows. The proposals have been agreed with the MUA.
1.2. The MUA have confirmed that there is adequate capacity within the existing downstream, public combined drainage system to receive the proposed foul flows. The proposals have been agreed with the MUA."
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2.4.5.1 The report further provides details on how the drainage proposals in terms of foul drainage and surface water drainage within the scheme is to be operated and how they met the requirements of the MUA within sections 5 and 6 of the report. Section 7 of the report also provides details on maintenance of surface water and foul water assets. This report is also supported by drainage designs and other technical drainage details for review by the MUA.
3.0 PLANNING POLICIES 3.1 The application site is within an area recognised as being an area of "Predominantly Residential Use" under the Area Plan for the East (Map 4), and the site is not within a Conservation Area. The site is not prone to flood risks, there are no registered trees on site and the site is not within a registered tree area, although it shares a boundary with the Glencrutchery Road Sports Field Registered tree area, with the trees within the site forming a congruent unit with the trees within the registered tree area.
3.2 Given the location of the site and the nature of the proposed development, the following parts of the Area Plan for the East Written Statement are considered relevant:
3.2.1 Section 6.5: Ensuring the efficient use of land and buildings "6.5.1 The density of development should be in keeping with the character of the local area. Higher densities will be more appropriate in the central areas of Douglas, Onchan, Laxey and Union Mills. Much of Douglas' celebrated seafront contains four and five storey hotels and apartment blocks which provide a distinctive visual image of the Capital and a highly practical form of space conscious living for a modern town.
6.5.2 Lower densities may be considered more acceptable in instances where there are site specific constraints, a need to provide additional levels of infrastructure or where the current character or appearance of the area necessitates a development of a lower density.
6.5.3 The subdivision of buildings for residential use can provide an appropriate source of housing and can lead to the more efficient use of existing buildings. Subject to other Strategic Policies, as well as the Proposals in this Plan, particularly in relation to amenity and the design of any alterations to allow the subdivision, such proposals will be supported.
6.5.4 In recent years, the Douglas town centre in particular has lost some of its population. The town effectively empties after the working day. Historically, people lived above the work spaces of shops, offices and workshops in Douglas creating a vibrancy that is perhaps lacking today. This Plan encourages the reintroduction of people living in the mostly vacant floors above the town's shops and offices12. More people living in the town will, it is hoped, create a more vibrant environment which will have a positive impact upon the day time and particularly, the night time economy within the town and will also enable us to respond to changes in new and emerging working patterns."
3.2.2 Section 6.6: Principles of good design 6.6.1 In the Strategic Plan, Strategic Policy 5 states that 'New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island'.
6.6.2 A positive contribution means making places which are attractive and safe areas to live, work and invest in. In order to achieve this, it is essential that detailed design proposals be based around an understanding of constraints and opportunities of the site and that the proposal responds positively to local context, in terms of its scale, form, layout, materials, colouring, fenestration and architectural detailing.
6.6.3 This, in turn, depends on good understanding of the local character of the individual settlements in the East. Local character is defined by the natural and physical features of an
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area, including its topography, the pattern of streets and public spaces, the street scene, the density of development, the scale and form of buildings and the materials used in construction.
6.6.4 Housing developments have been criticised in recent decades for their uniform and standardised appearance. In order to avoid creating homogeneous and sterile neighbourhoods, developers will be encouraged to incorporate a mix of property types of a varying scale, utilising a range of complementary materials wherever possible.
6.6.5 Similarly, the layout of development should encourage integration with surrounding areas and not be inward facing. Regarding extensions, it is recognised that the use of alternative materials and detailing in extensions and alterations can, in some case, enhance the character of an existing building and/or the surrounding area.
6.6.6 The layout, orientation and design of buildings can reduce the need for energy consumption by maximising the potential to secure the benefits energy provides e.g. heating, lighting and cooling, through alternative means. Where layout, orientation and design is not constrained or dictated by other factors i.e. by the character of the surrounding area or the juxtaposition of adjacent buildings, applicants for planning approval will be encouraged to demonstrate how the design of the development has reduced the need for energy consumption.
3.2.3 Urban Environment Proposal 3: "Development proposals must make a positive contribution to local character and distinctiveness. Traditional or contemporary approaches may be appropriate, depending upon the nature of the proposal and the context of the surrounding area."
3.3 In terms of strategic plan policy, the Isle of Man Strategic Plan 2016 contains the following policies that are considered specifically material to the assessment of this current planning application:
3.4 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; (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses; (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 (n) is designed having due regard to best practice in reducing energy consumption.
3.5 Environment Policy 3: Development will not be permitted where it would result in the unacceptable loss of or damage to woodland areas, especially ancient, natural and semi-natural woodlands, which have public amenity or conservation value.
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3.6 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."
3.7 Strategic Policy 2 states: "New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3."
3.8 Strategic Policy 3: "Proposals for development must ensure that the individual character of our towns and villages is protected or enhanced by: (b) having regard in the design of new development to the use of local materials and character".
3.9 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";
3.10 Strategic Policy 5: "New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases the Department will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies."
3.11 Environment Policy 42 states (In part): "New development in existing settlements must be designed to take account of the particular character and identity, in terms of buildings and landscape features of the immediate locality."
3.12 Housing Policy 4 states: "New housing will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions of these towns and villages where identified in adopted Area Plans..."
3.13 Transport Policy 1: New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes.
3.14 Transport Policy 4: The new and existing highways which serve any new development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan.
3.15 Transport Policy 6: "In the design of new development and transport facilities the needs of pedestrians will be given similar weight to the needs of other road users".
3.16 Transport Policy 7: "The Department will require that in all new development, parking provision must be in accordance with the Department's current standards."
3.17 Strategic Policy 10: New development should be located and designed such as to promote a more integrated transport network with the aim to: (a) minimise journeys, especially by private car; (b) make best use of public transport; (c) not adversely affect highway safety for all users, and (d) encourage pedestrian movement
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3.18 Energy Policy 5 - require proposals for more than 5 dwellings or 100 square metres of other development to be accompanied by an Energy Impact Assessment.
3.19 Previously Developed Land "Previously-developed land is that which is or was occupied by a permanent structure, including the curtilage of the developed land and any associated fixed surface infrastructure.' The definition includes defence buildings, but excludes: o Land that is or has been occupied by agricultural or forestry buildings. o Land that has been developed for minerals extraction or waste disposal by landfill purposes where provision for restoration has been made through development control procedures. o Land in built-up areas such as parks, recreation grounds and allotments, which, although it may feature paths, pavilions and other buildings, has not been previously developed. o Land that was previously-developed but where the remains of the permanent structure or fixed surface structure have blended into the landscape in the process of time (to the extent that it can reasonably be considered as part of the natural surroundings). There is no presumption that land that is previously-developed is necessarily suitable for housing development nor that the whole of the curtilage should be developed".
3.20 Paragraph 8.7.1 indicates that where optimum densities are set, they should not be used as argument for higher density development which have adverse effect on amenity of adjoining properties or character of area.
3.21 Paragraph 7.8.6 "Development which would affect any proposed or other recognised site of conservation value, including areas of ecological interest, will only be permitted where it can be demonstrated that: o the proposed development will not compromise the conservation objectives of the site or unacceptably harm its conservation value and its overall integrity; o there is proven public interest where safety or exceptional social or economic considerations outweigh the ecological importance of the site; and o the need for the development cannot be met in other less ecologically damaging locations or by reasonable alternative means.
3.22 Environment Policy 4: Development will not be permitted which would adversely affect: (a) species and habitats of international importance: (i) protected species of international importance or their habitats; or (ii) proposed or designated Ramsar and Emerald Sites or other internationally important sites. (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; or (iv) National Trust Land. (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. 3.23 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 and Community Policy 10.
4.0 OTHER MATERIAL PLANNING CONSIDERATIONS 4.1 Whilst not adopted planning policy, DEFA's Residential Design Guide (2021) is a material consideration in the assessment of this application as, "It is intended to apply to any residential development within existing villages and towns, including individual houses, conversions and householder extensions...". Sections 2.0 on Sustainable Construction, 3.3 on
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Transport Issues, 3.1 on Local Distinctiveness, and 7.0 Impact on Neighbouring Properties, are considered relevant to the current scheme.
4.2 IOM BIODIVERSITY STRATEGY 2015 TO 2025 4.2.1 The strategic aims (In part): o Managing biodiversity changes to minimise loss of species and habitats. o Maintaining, restoring and enhancing native biodiversity, where necessary.
4.2.2 Habitat loss actions "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."
4.3 Whilst not directly related to the application site, the Inspectors Report for a recent planning application within the locality which assesses some of the issues relevant to the current application under PA 21/01468/B is considered relevant for consideration. The Inspectors Report states the following on matters related to the character of the locality, as well as Trees and Biodiversity:
"69. The issue comes down to the layout of the development, particularly relating to Plots 1 & 2, along with the extent of the site coverage. The layout takes advantage of the depth of the appeal site by being designed to accommodate four dwellings backing onto the football ground to the west with two frontage plots onto Victoria Road. The two houses on Plots 1 and 2 would both side onto Victoria Road. Plot 1 would have a completely blank side wall facing onto Victoria Road and Plot 2 would include ground and top floor windows, but in both cases the houses would present a large uninspiring expanse of brickwork as the main roadside elevations.
The western side of Victoria Road in the vicinity of the appeal site, along with the Victoria Road frontage of the Little Switzerland Conservation Area are characterised by forward facing houses which directly address Victoria Road. This creates a strong sense of domestic living along the road defined by roadside homes of varying designs. As already indicated above, Lucerne Court is an example of a development which turns its back onto Victoria Road making little contribution to the streetscene.
The appeal proposal layout pays little regard to the character of Victoria Road in this location. It would present rather stark and visually uninteresting elevations to the road, the design emphasis being internalised into the creation of a contained cul-de-sac rather than a development which acknowledges and enhances the character and appearance of the wider streetscene, making a positive contribution to the character and appearance of the Island. In this way the proposed design layout would not respect the site, character and surroundings of the townscape24.
In considering the density of the proposed development I am conscious that an assessment of the density of an area is not just a numerical exercise. It requires an assessment of the character and appearance of the wider locality. Victoria Road does include a number of dwellings on ample plots. However, this does not characterise the whole length of Victoria Road. Development off to the south, including Sunnyside Cottage and Ballawana present a more tightly knit form of development. The appeal proposal similarly presents more modest homes on more limited plots. I do not consider this is a reason to reject the proposal, taking into account the terms of IMSP SP1 which requires development to make the best use of resources by optimising the use of PDL. However, this is not a reason to accept a quantum of development with a resultant layout which pays little regard to the character of the wider streetscene as already described above.
Trees/Biodiversity
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73. I am also conscious that the defined developable area set out by condition in the approval in principle 20/00293/A, was an area smaller than the appeal site. Tree licence 183/21, which sanctioned the removal of a number of trees in the area of the old air raid shelter, was conditional on the implementation of a mitigating scheme for the loss of the trees, replanting in a defined area on the License plan dated 20 April 2021. This area appears to include land which is now proposed to accommodate Plot 2, 3 and 4.
The proposed scheme still includes the mature trees in the southern corner of the appeal site (G1) which link through to the registered tree area just north of the western boundary with the Braddan AFC Clubhouse grounds. In considering the License details along with the site plan which identifies the trees permitted to be removed, it seems to me that in the demolition of the air raid shelter the permitted tree works of removal have been undertaken. The proposed scheme does include some additional tree planting, but much of this is towards the front of the site and is in mitigation for the loss of the frontage elm trees to facilitate the provision of the pedestrian footway. The planting of the odd cherry tree in each of the rear plots does not compensate for the removal of a significant number of mainly native trees which, along with the trees in G1, would have contributed to the verdant nature of this part of Victoria Road. The planting of the trees required by condition on the tree removal License would, in the main, be concentrated in the corner of the garden of Plot 2. Plot 2 also includes many of the new frontage Field Maple trees. It is likely that overtime residents of this property may experience issues around loss of light, overshadowing and autumn leaf fall which may result in pressure to cut back or remove some of the trees. No clear planting strategy has been provided to explain the location and spread of the mitigating trees across the site. The linkage through from the registered trees on the adjacent football ground, through G1 to the mitigating trees on the appeal site and, in particular, in the green shaded License area, should, in combination, make a significant contribution to the verdant character of Victoria Road. I am not convinced that this is the case, the design and layout of the appeal scheme being the predominant factor in where trees are to be accommodated.
Therefore, I consider that the appeal proposal by reason of a lack of clarity regarding appropriate mitigation for loss of trees and the resultant impact on biodiversity would diminish the quality of the wider locality and would adversely affect the character of the surrounding townscape as well as the nature conservation value of the site in the wider context.
Conclusion 84. Overall, the proposed quantum of development would result in a combined substantial weight of policy conflict, centred on unacceptable harm resulting from a lack of respect for the character of the surroundings of the appeal site, in conjunction with the harm to the biodiversity of the site and its surroundings, along with the identified adverse harm to the amenities of local residents. This is sufficient to tip the balance of this case against the appeal proposal, even when weighed against the contribution that the proposed six dwellings would have to the provision of new homes on the Island."
5.0 PLANNING HISTORY 5.1 There is no previous application for the site considered materially relevant to this application.
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 the proposal subject to planning conditions and separate s4 and s109(A) highway agreements, plus highway licences and temporary road closures/traffic management to cover construction (05 January 2023/7 March 2023). They state that planning conditions should cover:
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a) Access, visibility splays, off-site highway works and site layout to accord with Revised Proposed Site plan PL/10-01 rev B. b) Cycle parking at one space per bedroom.
6.2 Douglas Borough Council has indicated that they have no objection to the application. They further request that if suitable space can be found within the curtilage of the development, that the applicant gives consideration to the installation of community waste storage bins and community recycling bins as a potential alternative to residual waste bins and recycling boxes at each dwelling. The Council also recognises that having an EV charging point may impact negatively on the number of car parking spaces however they ask that consideration is given to the installation of the necessary infrastructure to allow for EV charging to be installed at a later date (18 October 2022/8 March 2023/24 March 2023).
6.3 Manx Utilities Drainage have made the following comments regarding the application (13 January 2023): They note that the application form states that scheme would will be using a soakaway for the surface water discharge, and state that if soakaways are going to be used, the applicants will need to demonstrate that the ground is suitable for a soakaway by carrying out a percolation test. They also indicate that they will need to see a copy of this before we can support the application. Further to the above, they state that they will require the foul drainage proposals.
6.3.1 In response to the request by Manx Utilities Drainage, the applicants have provided additional drainage information for review by the MUA.
6.3.2 Since the additional document were submitted by the applicants, no further consultation comments have been received from Manx Utilities Drainage.
6.4 DEFA Ecosystem Policy Team have made the following comments regarding the application: 6.4.1 Consultation dated 20 October 2022: o The Ecosystem Policy Team highlight the potential for legally protected roosting bats at this location and the potential for bats and their roost spaces, both of which are protected under the Wildlife Act 1990, to be damaged or destroyed by the proposed works.
o They recommend that due to location of this property in close proximity to Summerhill Glen broadleaved woodland, in an area with multiple bat records, and because of the stated condition of the building, a bat roost assessment is undertaken on the property by a suitably qualified ecological consultancy, prior to its demolition. This should be obtained in order to ascertain if and where bats are roosting within the building and therefore if and what avoidance and mitigation measures are required to protect bats.
o They note that if the decision is made not to get a bat assessment, then a thorough search of the building for bats must be made prior to demolition, which will require all external holes, crevices, lead flashing or loose tiles and roof voids, if present, to be investigated. Demolition without suitable checks would be considered reckless.
o They state that they are content with the proposals to remove the griselinia and cotoneaster hedge, because these are both invasive non-native plant species listed on Schedule 8 of the Wildlife Act 1990. They state that they are also happy with the choice of trees that are to be replanted. However, they note that in the short and medium terms, the loss of the trees and vegetation on site will result in a net loss for biodiversity, contrary to Planning policy, and therefore ecological mitigation is required.
o They recommend the following mitigation measures are incorporated on site:
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At least 1 bat roost brick suitable for crevice dwelling bats is installed high up under the eaves on either the south, east or west elevation of each of the new apartment buildings and we request that a plan is provided to Planning for written approval detailing the number, type and location of these bricks.
6.4.2 Consultation dated 27 January 2022: o They note that the Design and Access Statement was written before the updated site plans were provided. o They state that although they are happier with the proposed replacement planting as shown in the Revised Proposed Site plan, it is still not clear whether there is to be a new boundary hedge along the west and south of the site, and if so what species are to be used, because the site plan doesn't contain these details. They note that it would be helpful if these details are provided in a landscaping plan. o They also state that the applicants need to provide swift and bat boxes as mitigation and would prefer to see plans prior to determination of the application. o Furthermore, they state that they would be much happier if the applicants did a bat survey on the house and trees too.
6.4.3 Since the receipt of the comments from DEFA Ecosystem Policy Team no further ecological information on bats, hedges or trees on site have been provided by the applicants.
A condition requesting the provision of, and adherence to, a detailed tree protection plan, including protection of areas that will be planted.
6.6 Manx National Heritage have made the following comments regarding the application (21 October 2022): o They note that the application includes the removal of a number of trees, many of which are classed as category B and C indicating that they are of good physical condition and health. In addition there is a large lime tree at the entrance which is also to be demolished,
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should the application be successful. The trees are at various levels of maturity but none are registered and there is a plan for mitigation which involves the planting of native species.
o They state that they have concerns about the loss of breeding habitat to birds and possibly roosting bats and note that the mature trees will likely contain gaps in the bark which would attract roosting bats, especially where ivy has covered much of the trunk. It is suggested that the applicants have a bat survey carried out prior to this application being determined.
o They suggest that as the proposed development site supports a large number of trees. It is recommended that those that are to be felled or those close to the building works are checked for nesting birds prior to any works commencing.
6.7 The owners/occupiers of West Hill, Victoria Road, Douglas, object to the application on the flowing grounds: o The proposal is an over intensive development of the site that is neither consistent with, nor sympathetic to the surrounding area. o Impact on neighbouring amenity in terms of overlooking as any screening provided by the existing trees would be lost by the felling on all the trees on site. o Impacts on highway safety o Adverse visual impact of the development on the character of the locality o Adverse impacts on trees (14 Trees would be removed). o The site layout is contrary to the wrap-around garden layout that is predominant in the area. o The scheme would increase the floor area by about 3100sqft (287.9sqm). o The scheme would result in a significant increase in height over the current development on the site.
7.0 Assessment 7.1 The fundamental issues to consider with the current application are as follows: a. Principle of the development; b. Visual Impact; c. Impact on Neighbouring Amenity; d. Impact on highway safety; e. Impact on Trees; f. Impact on Biodiversity; g. Drainage; and h. Other Matters
7.2 Principle of Development (GP2, SP1, SP2, & HP4) 7.2.1 In assessing the principle of the proposed development, it is considered that the site is zoned for residential use on the Area Plan for the East which implies that the use of the site for residential purposes would be compatible with adjoining uses and conform to the general use of the area.
7.2.2 It is also considered that the site is within the settlement boundary and adjacent to and surrounded by existing residential dwellings; conditions which would ensure that residential development here broadly aligns with Strategic Policy 1 and Housing Policy 4. Whilst there is no presumption that land that is previously-developed is necessarily suitable for housing development nor that the whole of the curtilage should be developed, it is considered that the principle of utilising the site for residential development would be complimentary to the dominant residential use within the locality.
7.2.3 Additionally, the Isle of Man Strategic Plan 2016 seeks to locate new housing close to existing public transport facilities and routes, or where public transport facilities are, or can be improved, thereby reducing the need to use private cars and encouraging alternative means of transport. It is considered that the site would meet these goals given its proximity to existing
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routes within Douglas. While this does not signify a presumption in favour for all forms of housing development, it points to the fact the proposal would generally accord with the Strategic Plan goals for new housing on the Island. Therefore, in terms of the acceptability of the use of the site for residential development it is concluded that the proposal basically accords with the goals of Strategic Policy 1 and Housing Policy 4 of the Isle of Man Strategic Plan 2016.
7.2.4 The applicants have opined within the Design and Access Statement that the existing building is dilapidated, in poor condition and has no architectural value; a statement that points in the direction of the property being a brownfield site, and a basis for its replacement. However, there is no evidence to suggest that the existing building is not capable or renovation or at a state that it could not be made habitable again, and there is no evidence to support the building being derelict (as the need for repair does not imply classification as derelict). As such, it is not considered that the classification of the property as derelict bears sufficient weight in this case.
7.2.5 Given the above, it is judged that the redevelopment of this site for residential purposes is acceptable in principle. Albeit, the acceptability of the scheme proposed for the site would be dependent on further material planning matters as indicated previously, which need to be considered, to determine if the six (6) dwellings on the site would be appropriate for this site. It is also important that any development carried out here reflects the character of the site and this part of Victoria Road which is defined by large buildings laid out within large individual plots with mature landscaping. Development of this site should also consider that the trees on this site form an extension of the wooded landscape that stretches from the Playing Fields at St Georges AFC on Glencrutchery Road to the rear of the former Air Raid Shelter site to the south of the application site, and adjoining the boundary of the site and as such contribute further to the landscaped setting of the area, with its added ecological contributions to the area.
7.3 Visual Impact on the Site and Street Scene (GP 2, STP 3, EP 42, Sections 6.5 & 6.6 of TAPE, & RDG 2021) 7.3.1 With regard to the visual impacts of the proposed scheme, it would be vital to consider the requirements of Environment Policy 42 which stipulates that new development in existing settlements must be designed to take account of the particular character and identity, in terms of buildings and landscape features of the immediate locality, and General Policy 2 paragraph (b) which requires that new development should 'respect the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them'.
7.3.2 In assessing the visual impacts of the proposed development on the site, the key issues are the changes in building footprint and the general built footprint on the site, issues with the site layout and landscaping, as well as the quantum of built development on site which includes building heights, form and bulk.
7.3.3 In terms of the size (footprint) of the dwellings in relation to the existing dwelling on site, it is considered that building footprint would be reduced over the existing given that the building footprint would be reduced from about 320sqm (existing) to 289sqm when the three new building footprints measuring 97.9sqm, 95.7sqm and 97.5sqm are factored in. Notwithstanding the above, the total built footprint which includes the proposed building footprints, all hardstanding areas, and parking would be considerably increased over the existing from about 688sqm to 888.3sqm which is a 200.3sqm increase over the existing. It should be noted that the above does not factor in the relationship with the spaces between the buildings which serve to define the character of the site, as it would completely remove large areas of mature landscaping and garden areas which serve to define the site, increase the spread of development over the site area, with the layout which includes side-on building orientations further serving to create built development that would be at variance with the site
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character which supports a single building set out to conform with the general appearance of the area.
7.3.4 It is also important to note that the quantum of built development would be significantly increased over the existing as the three buildings which are all three storey buildings would replace the existing single two storey building with the scheme resulting in visual and actual overdevelopment of the site. It is also vital note that there is a potential for built development to be further increased on the site as individual owners make future modifications to the dwellings and further increase the built footprint; a situation that the current planning policies or planning conditions would not be able to prevent.
7.3.5 Moreover, these new buildings would completely dominate the site area and replace the existing green canopy which almost completely conceals the existing building on site, given that all the trees on site would be removed by the development; creating a site dominated by buildings whose layout and orientation do not in any way reflect the dominant character of the site. From the immediate streetscene along Victoria Road which is the highway access to the site, the three blocks of semi-detached dwellings, particularly the side-on buildings which pay little regard to the character of Victoria Road in this location will reinforce the divergence of the new built form to the site character, making the variation particularly noticeable.
7.3.6 With regard to the impact of the proposed development on the visual amenities of the area, it is considered that the information available does not lend support to ascertaining if the dwellings external finishes would be compatible with the character of the area. It is, however, worth noting that the photomontages which give an indication of the final appearance display materials, window designs, and external building designs which are completely at variance with the dominant character of the area characterised by buildings with red brick finish, slate tiles, hipped roofs, red and grey roof finishes, and traditional appearances which would further be at variance with the character of the dwellings within the immediate vicinity along Victoria Road, or those within Lucerne Court which back onto Victoria Road (and contribute little to the character of the streetscene, and as such would be contrary to part of Strategic policy 3(b) which requires that new development must ensure that the individual character of our towns and villages is protected or enhanced by having regard to the use of local materials, as well as Environment Policy 42 which stipulates that new development in existing settlements must be designed to take account of the particular character and identity.
7.3.7 Likewise, the size of the gardens, limited room for tree growth and cover within the proposed curtilages, and spaces between the buildings would not allow for the creation of large areas of landscaping which defines this part of Victoria Road, as it is likely that overtime residents of these new dwellings may experience issues around loss of light, overshadowing and autumn leaf fall which may result in further pressure to cut back or remove some of the replacement trees; creating an almost bare site relative to the general landscaped character of the area. Moreover, the development proposed would result in decline in the general character of the landscape or wider environment, given the overall scale of built development when assessed within the context of this part of Victoria Road which forms a strong connection with the adjacent wooded area, and whose particular character and identity in terms of buildings and landscape character is defined by large individual buildings laid out within large plots with mature landscaping, and as such would fail the requirements of Strategic Policy 4 (b).
7.3.8 Overall, it is considered that the site layout and spaces between buildings, landscape density and appearance, dominant building orientations, and quantum of built development would be averse to the existing built form within the site and surrounding area, and result in a layout which does not respect the character of the site and wider steetscene. The proposal is, therefore, considered to be contrary to the requirements of General Policy 2 (b, c & f), Strategic Policies 3, Strategic Policy 4(b), and Environment Policy 42.
7.4 Impact on Neighbouring Amenity GP 2 & RDG 2021
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7.4.1 In terms of the potential impact upon neighbouring properties, it is considered that the scheme has the potential to impact on the residential amenity of the occupants of West Hill situated directly south of the application site. This is hinged on the fact that the southern semi- detached block would be positioned only 7.1m from the northern elevation of this neighbour with this new semi-detached block which would be 9.5m tall rising 1.7m over the existing building which is 7.8m high and offering first floor and second floor views into private spaces on this dwelling and over the private garden areas for the neighbour (this does not factor in actual site levels over the established datum).
7.4.2 Whilst it is noted that an existing tree on the neighbouring property boundary would be retained, all the trees on the application site would be removed with the scheme offering no screening for the neighbouring dwelling for significantly long periods, particularly as it would take a long time for any replacement planting to be established on site.
7.4.3 As the new semi-detached dwellings would only be 3.9m from the boundary over the existing which is set 7.9m away with only a 3.85m wide projection moving closer to the dwelling at West Hill (with the broader elevation positioned about 17m away), it is considered that the new semi-detached block situated south of the application site would result in overbearing impacts when viewed from the side garden of West Hill. This impact is exacerbated by the fact that the existing mature landscaping on the boundary which serves to soften the relationship between both sites would be completely removed leaving a bear boundary with a projecting 9.5m built mass set only about 3.9m away.
7.4.4 Overall, it is considered that the proposed development, particularly the southern semi- detached block would result in adverse impacts on the amenities of the occupants of West Hill in term of overlooking and overbearing impacts, contrary to the provisions of General Policy 2 (g) and the principles promoted by the Residential Design Guide 2021.
7.5 Impact on Highway Safety (General Policy 2h & I, TP's 1, 4, 6, & 7, & SP 10) 7.5.1 In terms of impacts on highway safety, it is considered that the site entrance has been repositioned to be almost central on the site frontage, to achieve better visibility splays for the site with footpath added to the site frontage to further improve sightlines and safety for pedestrians. Therefore, it is considered that the proposed access alterations and sightlines would be an improvement over the current arrangement.
7.5.2 The new access arrangement and alterations to the site frontage would also facilitate safe access to the car park situated at the rear of the site and which serves the Braddan AFC Clubhouse as such is considered to be in the interest of highway safety for the general public.
7.5.3 In terms of off road parking, each dwelling would have at least 2 spaces provided within the site, with the proposal also seeking to provide cycle parking within the site which would be more than sufficient when compared with the requirements of Transport Policy 7. Besides, the site is within a public transport corridor which increases the public transport options available to future occupants.
7.5.4 Additionally, the applicants have provided a Stage One Road Safety Audit report and Road Safety Audit - Designers response which has been accessed and considered acceptable by DOI Highways. As well, Highway Services have considered the proposal and indicated that they do not oppose the scheme subject to appropriate conditions, and this points to the acceptability of the proposal in highway safety terms.
7.6 Impact on Trees (GP 2, EP 42, EP 3) 7.6.1 In considering potential impacts on trees on the site, it is noted that the current scheme would result in the removal of all the trees on site including four Category B trees, and this is considered to weigh against the proposal. However, DEFA Arboricultural Team have advised that they have not objected to the removal of the category B trees due to each tree being
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unsuited to the setting and thus unsuitable for retention in the long-term. They have also advised that all the other trees marked for removal are of poor quality, and that suitable mitigation has been proposed to justify the impact of their removal.
7.6.2 Given the above, it is considered that the removal of the trees on site would be acceptable in arboricultural terms, although appropriate conditions would be imposed to ensure that the recommended mitigations are provided within the scheme should approval be granted.
7.6.3 The above however does not in any way prejudice the assessments regarding the amenity value of the trees and their contributions to the general character of the area identified by its verdant nature.
7.7 Potential Impact on Biodiversity (EP 4, 5 & GP 2) 7.7.1 In terms of the ecological impacts of the proposed development, it is considered that the application is not supported by any ecological information which would serve to provide insights into the potential ecological impacts of the proposal on site ecology and ensure mitigation measures are integral to the development, in order to ensure that the scheme does not result in net loss of biodiversity. It should be noted that the site has significant vegetative cover of both trees and shrubs which provide valuable habitat for biota, including protected species which may inhabit the site particularly as the site has not be occupied for some time and as the existing mature landscaping forms a congruent unit with the surrounding wooded area which adjoins the site and is known to have multiple bat records. In this respect, it is felt that the application fails to satisfy the principles of Paragraph 7.8.6 and Environment Policy 4 of the IOM Strategic Plan.
7.7.2 The potential impacts upon biodiversity of the site as a direct result of the tree loss on site is further exacerbated by the fact that all the trees on site would be removed which would imply that the development would isolate patches of habitats surrounding the site and make the site redundant for migratory species which currently use the existing vegetation on site as migration corridors. Whilst it is noted that the scheme seeks to reintroduce replacement planting, these would only be possible after construction work has been concluded on site given the quantum of built development proposed, thus creating long periods of habitat absence which holds the potential to completely forestall future biota colonisation of the site area. This concern has also been highlighted by DEFA Ecosystem Policy Team who note that in the short and medium terms, the loss of the trees and vegetation on site will result in a net loss for biodiversity, contrary to Planning policy, yet no ecological information has been provided to indicate how this impact would be managed in the short and medium term (save for the site plan which shows that new plants would be introduced on site). There is also no information on how the plantings would be introduced or the management plan for these plantings. As such, it is considered that this element of the proposal would be contrary to the IoM Strategic Plans Strategic Policy 4 (b), and Strategic Objective 3.3 Environment (b), as well as the habitat loss action 21 of the IoM Government Biodiversity Strategy.
7.7.3 Whilst the arguments put forward by the applicants that the existing trees have outgrown their environment and should be felled and replaced with more appropriate species, this does not in any way depreciate the ecological value of the existing trees and shrubs on site. As the existing trees and shrubs serve as valuable habitats on site (given their existing densities and undisturbed nature), it is considered that their removal would result in the destruction of existing habitats on site, with this impact considered to be significant given that it is not established how new planting would be safety and appropriately integrated on site as mitigation for biodiversity loss, with minimal impacts on site ecology.
7.7.4 Accordingly, it is considered that the development as proposed would fail to comply with the requirements of Environment Policies 4 and 5, and General Policy 2 (d) of the Strategic Plan.
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7.8 Drainage (GP 2l). 7.8.1 With regard to drainage for the site, it is considered that the proposal includes a detailed drainage management scheme for the site area, which has been assessed by MUA Drainage, who have stated that they would require additional information to demonstrate that the ground is suitable for a soakaway by carrying out a percolation test, as well as requiring the applicants to provide foul drainage proposals. Whilst the applicants have provided additional information to address these concerns, no further comments have been received from MUA Drainage, although the applicants note in their documents that MUA Drainage is satisfied with the submissions.
7.8.2 Additionally, the site is not prone to flood risks which could exacerbate drainage challenges for the site, and it is noted that the site topography is such that would not create concerns with rapid surface water flows. Based on the foregoing, it is considered that the any drainage challenges for the site would not be sufficient to warrant refusal of the scheme.
7.9 Other Matters 7.9.1 Designing out Crime (CP 7 & GP2m) 7.9.1.1 In terms of designing out crime and antisocial behaviour, it is considered that the new residential curtilages have been clearly marked out so that visitors to the site can easily identify the properties they seek to visit. Likewise, the new dwellings are positioned such that there are overlooking views from the front of the dwellings which would serve to promote community surveillance. Besides, no new confined spaces with easy access to those outside the site would be created, which would serve as easy hideouts for criminal activity or antisocial behaviour. When these elements of the proposal are assessed against the requirements of General Policy 2 (m) and Community Policy 7, it is considered that the proposed development complies with the relevant policies.
7.9.2 Fire Safety (CP10 & 11) 7.9.2.1 In terms of fire safety, it is considered that the site layout is such that would enable easy access into the site for fire-fighting vehicles should they be required. Likewise, the scheme provides sufficient offsets from the boundaries which ensure that access to rear of the new dwellings is not impeded in case of fire since there is provision for access to the rear of all the dwellings, with a clear break created between the properties, which would be sufficient to prevent easy spread of fire. As such, it is considered that these elements of the scheme aligns with the requirements of Community Policies 10 and 11.
7.9.3 No other concerns have been noted.
8.0 CONCLUSION 8.1 The following issues weigh in favour of the proposal; the zoning of the area for residential development, the acceptable highway safety impacts, the approach to designing out crime and prevention, and preventing fire safety. Conversely, the following issues weigh against the proposal; the potential adverse impacts upon the visual amenities of the area and townscape, the adverse impacts on ecology, and impact on the occupants of West Hill, Victoria Road.
8.2 Overall, it is considered that whilst there are factors which weigh in favour of the proposal, the proposed quantum of built development which would conflict with site character, the fact that the development would not respect the character of the locality and townscape to which it is to be established, the adverse impacts on the neighbouring amenity, and lack of information to ensure the protection of site ecology, the application is recommended for refusal, as it would fail the requirements of General Policy 2 (b, c, d & g), Environment Policies 4, 5 and 42, and Strategic Policy 3(b), and Strategic Policy 4 of the Strategic Plan.
9.0 INTERESTED PERSON STATUS
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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: 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
9.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status. __
I can confirm that this decision has been made by a Principal Planner in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded Interested Person Status.
Decision Made : Refused Date: 20.06.2023
Determining officer Signed : C BALMER
Chris Balmer
Principal Planner
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