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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. 23/00126/C Applicant : Mrs Fiona Cregeen Proposal Use of Field 534492 for camping purposes (retrospective) Site Address Field Number 534492 Glen Dhoo Hillberry Onchan IM4 5BJ
Case Officer :
Mr Paul Visigah Photo Taken :
Site Visit :
Expected Decision Level Planning Committee
Recommendation
Recommended Decision: Refused Date of Recommendation 10.05.2023
Reasons for Refusal
R : Reasons for Refusal O : Notes attached to reasons
R 1. The Department is not satisfied that there is sufficient justification for the proposed development to warrant setting aside the presumption against development outside areas zoned for development. As such, the proposal is concluded to represent unwarranted development that is detrimental to the amenity of the countryside contrary to the provision of General Policy 3, Environment Policy 1 and Business Policy 14 of the Isle of Man Strategic Plan 2016.
R 2. No information has been provided to demonstrate that there are no other reasonably acceptable alternative sites or that there is an overriding national need for a campsite of this standard in this specific location. The proposal would result in an unacceptable and unwarranted loss of agricultural land without suitable justification contrary to Environment Policy 1 and General Policy 3 which seek to protect the countryside for its own sake and it is not demonstrated that the development would not present a substandard facility contrary to the principles of the Department for Enterprise IOM Destination Management Plan 2016-2020 and Non-Serviced Accommodation Futures Study (March 2017).
R 3. The proposal would undermine established policies of the Strategic Plan which indicate that development which is likely to have a significant effect on the environment will be required to be accompanied by an Environmental Impact Assessment and suitable supporting environmental information, as no Environment Impact Assessment or supporting environmental information has been provided. The proposal would therefore be contrary to Environment Policy 24 of the Strategic Plan.
R 4. The application does not provide sufficient information to properly judge the impact of the development on the soils within the application site, even though soil degradation associated camping could be a concern with the proposal. The application also does not show how camping could be implemented without having detrimental impacts on the biodiversity within
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the site and adjoining mature landscaping on the site boundary, or how this impact will be mitigated. Therefore, it is, considered that the scheme as proposed would be averse to the requirements of Environment Policy 1 and Environment Policy 4 of the Strategic Plan.
R 5. It has not been fully demonstrated that the proposal and the expected increase in traffic at the site can be suitably accommodated without detriment or harm to the highway safety of the area, contrary to Transport Policy 4. __
Interested Person Status - Additional Persons
It is recommended that the following Government Departments should be given Interested Person Status on the basis that they have made written submissions relating to planning considerations:
Department of Enterprise (Tourism Division) __
Officer’s Report
THIS APPLICATION IS REFERRED TO THE PLANNING COMMITTEE AT THE REQUEST OF THE PRINCIPAL PLANNER
1.0 THE SITE 1.1 The application site represents Field Number 534492, Glen Dhoo, Hillberry which sits on the western side of the Mountain Road and at the junction between Ballacottier Road and Mountain Road. The field measures 1.43 Hectares in area.
1.2 The site has most of its boundary enclosed in mature landscaping comprising sodbanks and mature trees, with its southwest, southeast and sections of its eastern boundary comprising mature trees. The site rises towards the northern boundary with parts of the northern sections of the field viewable from the Mountain Road.
2.0 THE PROPOSAL 2.1 Planning approval is sought for Use of Field 534492 for camping purposes (retrospective). The applicants state on the application form that retrospective change of use of field no. 534492 is being sought as an extra field for camping for Glen Dhoo Campsite from 1 April to 31 Oct. They note that the field has been used since c.1970 for camping together with field no. 534107, for which Planning Dept. has evidence of planning approval, and field no. 534127, which has IDO 28393 in place but has not been used since c.2000 for camping, nor is there any intention to use it again.
2.2 They also state the following in the Covering Letter dated 7 February 2023: o Glen Dhoo Camping Site was established in the mid-1960s. o It has operated continuously since then, except in 2001 due to foot-and-mouth disease and in 2020 and 2021 due to the Covid pandemic. o The top field has planning with no time related restrictions. o The primary field used for camping is Field 534107, which has been used since the campsite opened up until the present day. Field 534492 was used since around that time also. Both fields would have been used for the full season from 1st April until 30th September. o Field 534127 was used from the time that its approval was granted until the year 2000. It is not intended to continue the use of Field 534127. o In 2006, due to their parent's age and decreased demand in the summer season, the decision to only open the camping site for the TT and Manx Grand Prix using Fields 534107 and 534492 was made.
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o They want the planning approval to have no time related restrictions as is the case for Field 534127, so that the opening period can include the school half-term holiday in October. o Only approximately 50% of Field 534492 can be used for camping as other parts of it are too steep.
2.3 The application is provided with photographs showing campers using the application field and it is suggested that this photograph was taken in 2017, although there are no date stamps to show this. A number of documents including receipts, booking forms, advertisements, and brochures have been provided to indicate that the broader site area has been operating as a camping site for a long time.
2.4 The application is further provided with supporting information including a site plan setting out the positions of drinking water position and position of gated access to the field. A location plan marks out areas of field that are suitable for camping, as well as the fields that have been granted approval for use as camping sites, including field 534127 which they would seek to discontinue its use as a campsite, although no reasons has been given for discontinuing the use of this field for camping.
2.5 The site is within 9m of a watercourse and it is not indicted that any tree would be removed as part of the proposal.
2.6 Whilst the scheme seeks use of the field as a permanent camp site, no environmental impact assessment and suitable supporting environmental information has been provided. It is also not indicated if there would be extensions to the existing amenities on site or erection of new amenity facilities on site to cope with increased visitors to the site. Additionally, the scheme does not detail proposed number of pitches to be allowed on the site, details of opening hours, details of waste collection provision or details of lighting for the site.
3.0 PLANNING POLICY 3.1 The application site is not designated for any particular purpose under the Area Plan for the East (Map 6 - Onchan), and the site is not within a Conservation Area. The site is not prone to flood risks or within a Registered tree area and there are no registered trees on site.
3.2 The Character Appraisal within the Area Plan for the East states thus concerning the area Onchan (D3): 3.2.1 Landscape Strategy: "Conserve and enhance: a) the character, quality and distinctiveness of this area of relatively sparse settlement; b) its valley bottom woodland; c) its National Glens; d) the various archaeological features within the area
3.2.2 Key Views Dramatic views to an Upland backdrop to the North and West. Dramatic, panoramic views eastwards across the ever-changing colour and nature of the sea and sky, contribute to strongly recognisable sense of place. Close and distant views to the northern edge of Onchan/ Douglas settlement, which is visually harsh in places. Channelled views along the corridor of the Groudle River, which is enclosed in places.
3.3 The following parts of the Area Plan Written Statement are considered relevant: 3.3.1 Paragraph 10.5 (i) on 'Area Plan desired outcomes' states the following concerning camping: "To support camping in the East, but only where tented sites and seasonal accommodation would occupy suitable sites, ensuring that proper access, safety and sanitation can be achieved along with reasonable amenity for all."
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3.4 In planning terms, there is no provision within the Strategic Plan to support new camp sites and tourist development is treated the same as any other form of development in the countryside, as the Strategic Plan stipulates a general presumption against development in areas which are not designated for development and where the protection of the countryside is of paramount importance (EP 1 and GP3). However, it is recognised that camping is becoming an important part of the Island's tourist attractions and an increasing popular form of tourist accommodation and understood that Department of Enterprise (Tourism Division) is supportive of initiatives which attract and accommodate more visitors to and on the Island. Encouragement is given for such facilities to be grouped near to existing buildings and where possible, to complement existing operations on the same site.
3.5 Given the above, it is important to consider the following parts of the strategic plan: 3.5.1 Strategic Policy 8: Tourist development proposals will generally be permitted where they make use of existing built fabric of interest and quality, where they do not affect adversely environmental, agricultural, or highway interests and where they enable enjoyment of our natural and manmade attractions.
3.5.2 Paragraph 9.5.3: "It is considered that the Island's primary assets to tourists and visitors alike are its unique historical landscape, culture and heritage, as well as a wide range of specialist events and attractions. Many activities and facilities providing for the Island's tourists require no permanent development: the TT Races, for example which attract by far the most significant number of tourists to the Island of any event held here, require little but the Grandstand on Glencrutchery Road and a small number of modest marshals' shelters around the Course. Tourism can, however require the erection of built structures - holiday accommodation being the most frequently requested form of new development required in association with the tourism industry. It is important that a balance be struck between the needs of tourism and the protection of these assets, and that tourism development should be sustainable in accordance with the objectives of this plan. There is no special reason why less demanding policies should be applied to tourism development than for other types of development in the countryside, and larger scale schemes may have to be the subject of an environmental impact assessment before planning permission is granted, as with any other form of large scale development.
3.5.3 Business Policy 11: Tourism development must be in accordance with the sustainable development objectives of this plan; policies and designations which seek to protect the countryside from development will be applied to tourist development with as much weight as they are to other types of development. Within the rural areas there may be situations where existing rural buildings could be used for tourist use and Environment Policy 16 sets out the circumstances where this may be permitted.
3.5.4 Business Policy 14: Tourism development may be permitted in rural areas provided that it complies with the policies in the Plan. Farmhouse accommodation or quality self-catering units in barn conversions and making use of rural activities will be encouraged but must comply with General Policy 3 and Business Policies 11 and 12. Other forms of quality accommodation in rural areas will be considered, including the provision of hostels and similar accommodation suitable for walkers but must comply with General Policy 3 and Business Policies 11 and 12.
3.5.5 Developments which are likely to have a significant effect on the surrounding environment are also required to provide an Environmental Impact Assessment and suitable supporting environmental information (Environment Policy 24) which assesses the likely environmental effects of a proposal. Appendix 5 of the Strategic Plan lists the types of development that require an EIA in every case; this includes permanent campsites and caravan sites listed under items (j) Other Projects.
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3.5.6 Environment Policy 14: Development which would result in the permanent loss of important and versatile agricultural land (Classes 1-2) will not be permitted except where there is an overriding need for the development, and land of a lower quality is not available and other policies in this plan are complied with. This policy will be applied to (a) land annotated as Classes 1/2 on the Agricultural Land Use Capability Map; and (b) Class 2 soils falling within areas annotated as Class 2/3 and Class 3/2 on the Agricultural Land Use Capability Map.
3.5.7 Strategic Policies 4 and 5 relate to preserving the character of the landscape, preventing unacceptable environmental disturbance, and making positive contributions to the environment of the Island.
3.5.8 Environment Policy 4 and 5 protects ecology.
3.7 Other relevant policies within the Strategic plan include: 3.7.1 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
3.7.2 Environment Policy 22: Development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties in terms of: iii) vibration, odour, noise or light pollution.
3.7.3 Community Policy 7: The design of new development and the extension and refurbishment of existing buildings and development must, as far as is reasonably practical, pay due regard to existing best practice so as to help prevent criminal and anti-social behaviour.
4.0 OTHER MATERIAL CONSIDERATIONS 4.1 Isle of Man Non-Serviced Accommodation Futures - Final Report 4.1.1 Planning Policy Recommendations "In terms of defining what is meant by 'overriding national need', we have suggested a number of tests or criteria that could be considered in terms of: o Extending the season/attracting visitors outside the main May-September period; o Serving and helping attract target markets - accommodation aimed at families, empty- nesters, walkers, cyclists etc.; o Securing and attracting investment from both Island and off-island developers and investors - with developers signed up; o Showing 'additionality' in terms of providing something not already offered on the Island; meeting an identified gap in supply; attracting new markets rather than diluting existing ones; or bringing an established national or international brand name to the Island and all that brings with it in terms of profile, customer databases, and the ability to drive new demand through marketing, central reservations and customer loyalty schemes; o High quality, distinctive accommodation provision; o Spreading tourism activity and benefit geographically across the Island; o Encouraging longer stays and greater visitor spend as a result; o Inclusivity and contributing to the health and well-being agenda, e.g. the provision of accessible accommodation, provision for outdoor activities, accommodation that helps connect with nature; o Environmental sustainability in terms of eco-friendly accommodation development that respects, protects and enhances the Island's landscape and natural environment and develops its reputation as a sustainable tourism destination".
4.1.2 7. Opportunities by Type of Non-Serviced Accommodation "Campsites
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o The upgrading of some of the Island's campsites to a 4 or 5 star standard, to enable them to compete more effectively for off-island business. This would include high quality, heated toilet and shower facilities, a covered dish washing area, pitches with electric hook ups and hard standing areas to allow campers to park next to their tent, and other on-site facilities such as drying rooms, a campers' kitchen/covered cooking area, children's indoor and outdoor play areas, a launderette, Wi-Fi, cycle and motorbike storage, and perhaps a bar and/or café.
o The expansion of some campsites, if they have land available to extend onto, for which they can achieve planning permission.
o Some new 5 star sites, although the upgrading of existing sites would seem a more sensible route to pursue.
o Camping provision in the south of the Island, given the current lack of provision here."
4.2 Isle of Man Visitor Economy Strategy 2022-2032 4.2.1 The Strategy's headline targets are to grow the annual visitor numbers to 500,000 by 2032 and increase the annual economic contribution of the Island's Visitor Economy to £520m. This will mean attracting an additional 170,500 visitors per year compared to 2019. The aim is to triple the holiday and short break market as well as grow all of the other visitor markets. Combined with an expected increase in average spending per visitor, driven by strong growth in longer staying and higher spending leisure markets, these visitor numbers should result in a more than doubling of annual visitor spending on the Island to £310m, which will support an increase in Visitor Economy jobs to 5,000 and generate an annual Exchequer benefit of £49m.
4.2.2 Programme 3: Visitor Accommodation Transformation A key aspiration is to widen our non-serviced accommodation supply with the introduction of the innovative offers that are finding a strong market in competitor destinations, such as back- to-nature retreats, lifestyle and wellness resorts, sea cabins, treehouses, sky huts and luxury glamping sites.
4.3 Planning Policy Statement (PPS): Planning & the Economy (A Consultation Document February 2012) 4.3.1 "In applying the provisions of the Strategic and Area Plans, particularly General Policy 1 and General Policy 3 of the Strategic Plan, the Department will seek proposals to be supported by evidence that demonstrates that the proposed development would secure sustainable, long term economic growth of Island wide benefit, which meets the wider objectives of sustainable development by weighing market and other economic matters alongside environmental and social costs and benefits."
4.4 IOM Biodiversity Strategy 2015 to 2025 4.4.1 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.
4.4.2 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."
5.0 PLANNING HISTORY 5.1 The current application site has not been the subject of any previous planning application although the broader site area has been the subject of previous planning application that are considered relevant in the assessment and determination of the current application.
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5.2 PA 86/00994/B for alterations and extensions to existing toilet/shower block, Glen Dhoo Camp Site, Hillberry, Onchan. This was approved by the planning Committee on 14 November 1986.
5.3 Planning approval was granted for extension to amenity building, Glendhoo camp site under PA 93/00608/B. This was approved by the Planning Committee on 3 September 1993. This enabled the increase capacity of the amenity building to serve the broader site area.
5.4 Approval was granted in 1996 under PA 96/01196/B to allow the formation of holiday accommodation in existing outbuilding, Glendhoo Campsite. This increased the range of tourist accommodation offering within the campsite.
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 find the application to have no significant negative impact upon highway safety, network functionality and /or parking. They request that if appropriate, restrictions to use to should apply, e.g. for extent of a season (24 February 2023).
6.2 DofE Tourism Division have made the following comments regarding the application (10 May 2023): o The Our Island Our Future Visitor Accommodation Transformation Strategy 2022-2032, endorsed by Tynwald in May 2022, includes a Visitor Accommodation Transformation Action Programme that seeks to develop 500 new and transformed hotel and serviced accommodation bedrooms and 500 new units of distinctive, contemporary, eco-friendly non-serviced accommodation to support visitor number growth over the next 10 years.
o Campsites continue to be a popular choice of accommodation for visitors and locals alike and are required to ensure the Island has enough bed stock to support the visitor growth to 2032.
o Glen Dhoo Campsite has been registered as a campsite with Visit Isle of Man for a number of years with 70 pitches.
o For the reasons set out above, Visit Agency Officers have no objection to this proposal.
6.3 DEFA Fisheries have indicated that they have no objections to this development from a fisheries perspective (23 February 2023).
6.4 Onchan Commissioners have recommended that the application be approved for planning purposes only (6 January 2023).
6.5 No comments have been received from neighbouring properties.
7.0 ASSESSMENT 7.1 The fundamental issues to consider with the current application are: a. The principle of the proposed development; b. The visual impact of the proposed campsite; c. Environmental impacts; d. Amenity Impacts; e. Impacts on Biodiversity; and f. Impact on Parking and Highway safety
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7.2 THE PRINCIPLE (GP3, EP1, BP 11, Strategic Policy 8 & Paragraph 9.5.3 of the Strategic Plan, and Paragraph 10.5 (i) of Area Plan) 7.2.1 The Strategic Plan is clear that tourism development shall only be supported where it complies with the relevant planning policies of the Strategic Plan and any proposal on land not designated for development such the case with the current application first needs to fully demonstrate that there are no other alternatives available (such as alternative sites) and that the proposal is of sufficient national need as to outweigh the tests of those policies which seek to protect the Islands countryside from unnecessary and unwarranted development (EP1 and GP3).
7.2.2 The have indicated that they intend to extend the camping activities into the application field on a permanent basis all year round, with the new camping site serving as a replacement site for field 534127 which is suggested to have planning approval for use as a temporary campsite, together with Field 534107 which is the main campsite with existing facilities and amenities to support camping. Whilst the above are relevant as references of use of the broader site area for camping activities, the exceptional basis on which the previous approvals were granted approval hold less weight with the current application, considering the current scheme seeks permanent use of an agricultural field in excess of 1 hectare for camping purposes and as such must be considered on its own merit. In addition, the proposal needs to evidence the specific national need for the proposed campsite and in this specific location, in addition to demonstrating that the scheme would not result in adverse environmental impacts as required by Environment Policy 24 and Appendix 5 of the Strategic Plan.
7.2.3 From review of the submitted documents, the application contains no information as to what other sites have been considered and or discounted as part of the design process and it is therefore unknown if there would be any other alternatives sites more appropriate for the proposed development. It also does not state why Field 534107 which is suggested to have planning approval is no longer suitable for camping purposes or why its use is to be discontinued. Beside the evidence that there have been previous bookings for the existing campsite (shown on receipts) and use for previous camping events, revenue generated and amount spent on electricity, and evidence of receipts for 2022 bookings, the application contains no information in terms of the previous uptake or demand of the existing campsite, current camping demands which justify extending camping uses into the application site or a business plan to demonstrate that the proposed development would secure sustainable, long term economic growth of Island wide benefit, which meets the wider objectives of sustainable development by weighing market and other economic matters alongside environmental and social costs and benefits as set out in the Draft PPS on the Economy 2012 in delivering prosperity, jobs, diversification and economic growth across the Island.
7.2.4 When the proposal is weighed against the requirements of the Isle of Man Visitor Economy Strategy 2022-2032, which has a key aspiration to widen the non-serviced accommodation supply with the introduction of the innovative offers that are finding a strong market in competitor destinations, such as back-to-nature retreats, lifestyle and wellness resorts, sea cabins, treehouses, sky huts and luxury glamping sites, it is not considered that the application meets the criteria set as innovative offers within this documents. Firstly, the proposal does not represent a back-to nature retreat site or represent a lifestyle or wellness resort. Additionally, there are no tree houses, sky huts or luxury glamping provisions within the scheme. The application has also not demonstrated why it should be exempt from meeting these requirements, save for the indicating that it seeks to increase camping provisions on a permanent basis within the application site which has been used retrospectively for camping purposes.
7.2.5 The proposal is also not judged to represent an upgraded campsite that would achieve a 4 or 5 star standard which is sought by the Isle of Man Non-Serviced Accommodation Futures - Final Report, with capacity to compete more effectively for off-island business. This is hinged on the fact that there is no evidence to suggest that the site provides high quality, heated toilet
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and shower facilities, pitches with electric hook ups and hard standing areas to allow campers to park next to their tent, and other on-site facilities such as drying rooms, a campers' kitchen/covered cooking area, children's indoor and outdoor play areas, a launderette, Wi-Fi, cycle and motorbike storage, and perhaps a bar and/or café, even though it seeks to extend into adjacent land.
7.2.6 Therefore, as the proposed development does not offer or provide information to demonstrate that it would be a campsite that offers a limited range of the facilities outlined in the Non-Serviced Accommodation Futures document in trying to upgrade the quality of the Islands campsites, there is no demonstrable economic benefit and the standard as shown within the application is not sufficient enough to warrant the campsite being of such exceptional quality or overriding national need as to outweigh the test of the policies. This, together with the other gaps (failings) that have been identified in paragraphs 7.2.1 to 7.2.4 demonstrates that the principle of the proposed use is not acceptable. This, however, does not in any way denote automatic refusal for the proposal as other matters identified in 7.1 above would need to be considered to determine the suitability of the proposal for the site.
7.3 VISUAL IMPACT (EP2) 7.3.1 In terms of visual impacts, it is considered that the site is not situated directly adjacent the Mountain Road which is the main arterial serving the site, although it is noted that there would be views attainable to the site from sections of the Mountain Road directly adjacent the Glen Dhoo junction. It is, however, noted that there would be limited views to large sections of the application site due to the trees along the site boundary which serve as buffers from the highways.
7.3.2 Whilst it is noted that large sections of the site would not be viewable from large sections of the Mountain Road, the site would also visible from sections of the Scollag Road situated west of the site. Therefore, as the permanent use of the site would result in a continuous turnover of camping paraphernalia, the long term impact of which would have a significant adverse visual impact on the rural context and enjoyment of the site and as such is considered significant over the existing use as an agricultural field. Granting the temporary campsite within Field 534127 has been considered acceptable this is only for a short period of time during the year. Thus, the current proposal would step significantly outside of this remit and is considered to result in adverse impact on the visual quality of the area, although the intensity of this impacts has not been quantified as there is no supporting environmental information or associated Environmental Impacts Assessment to facilitate a thorough assessment of the visual impacts resulting from the scheme.
7.3.3 Based on the foregoing, it is not considered that the visual impacts resulting from the proposal would be acceptable.
7.4 ENVIRONMENTAL IMPACT (EP24) 7.4.1 Appendix 5 of the Strategic Plan 2016 makes reference to the types of applications that require an Environmental Impact Assessment including permanent campsites, and until such a time that a Planning Policy Statement (PPS) is prepared specifying the manner in which the Department intends to deal with these applications, they are to be considered against the UK Town and Country Planning (Environmental Impact Assessment) Regulations 2017. Schedule 2 of these Regulations states that a permanent campsite or caravan sites that exceed 1 hectare must provide an EIA, with the application site falling within this threshold at 1.43hectares.
7.4.2 The provision of an environmental impact report would have provided clarity on potential impacts on the environment and details of mitigation measures that could serve to ensure that the proposal could be established on site without creating undue impacts on the site in terms of noise, waste, lighting and ecological impacts. However, this has not been provided and as such the proposal is considered to fail the requirements of Environment Policy 24 and Appendix 5 of the Strategic Plan 2016. Moreover, the unacceptable loss of an
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agricultural site without overriding need or alternatives being demonstrated, and the fact that it has not been demonstrated that the proposal would enable the enjoyment of the islands natural and man-made attractions are considered to fail Strategic Policy 8.
7.5 AMENITY IMPACT (EP 22, CP 7 & Paragraph 10.5 of TAPE) 7.5.1 Environment Policy 22 requires that development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties. In this case, as with most camping sites, the main concern is likely to be noise with the most noise generated likely to be over the summer months and at the height of camping season, with many gathering to socialise and enjoy the outdoors, with its associated music. Whilst many campers would be considerate of nearby properties and surroundings and generally act in good behaviour, there is no guarantee that this would always be the case. However, the nearest residential property 'Red House' is under ownership of the applicant, where it is considered that the occupants would already be accustomed to living by campers with necessary adjustments made to accommodate the changes associated with campers in the vicinity.
7.5.2 It is also considered that beside 'Red House', the next nearest residential property 'The Beeches' is situated about 68 away from the southern camping locations within the application site and as such it is not considered that the proposed camping activities would significantly impact this property, particularly as the intervening mature landscaping and the Mountain Road which supports heavy traffic separates both properties. As such, any impacts in this case would be negligible.
7.5.3 Additionally, it has been considered that the coming and goings to the site will increase considerably over the existing situation with Field 534127 which is only used on a temporary basis, with potential to exacerbate impacts over existing thresholds on nearby properties. However, there is already a level of activity in the area through the existing campsite and with the site being on an main route with high volumes of passing traffic, it may be that additional comings and goings as a result may not be so extreme as to cause any new or significant amenity harm on the surrounding residents as to warrant a refusal.
7.5.4 In this respect, it is considered that the proposal would comply with the requirements of Environment Policy 22 and Community Policy 7 of the Strategic Plan.
7.6 IMPACTS ON BIODIVERSITY (EP4 & 1). 7.6.1 In terms of ecological impacts, it is noted that the DEFA Biodiversity team has not made any comments on the application. However, it is considered that the use of the existing agricultural field as a permanent camping site holds potential to generate impacts on the vegetation within the Feld, and habitats within the trees and mature landscaping that border the site, in terms of light, noise and vibrations due to the siting of camping pitches in close proximity to rarely disturbed habitats. As well, soil compaction which is a key occurrence with many camp sites on fields is also expected to increase with the permanent use of the site for camping, thus limiting the soil potential to support existing biota on site.
7.5.2 It has been considered that an argument could be made that if the field is left solely for agricultural use, there would be some form of disturbance. However, the use of the field for grazing of animals (which is the dominant use of the fields in the area) would in no way result in continuous soil compaction as would be the case with a permanent campsite. As such, it is considered that the permanent use of the site for camping purposes would exacerbate the ecological impacts beyond that associated with normal agricultural processes which the soils have been accustomed to.
7.5.3 Likewise, the scheme has not been supported by an environmental statement or any ecological information that would give a detailed assessment of the ecological disturbance or potential impacts that could result from the development. Besides, sufficient justification of need has not been made to allow the loss of the agricultural field, and it has not been
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established that there are no suitable alternatives. Therefore, it is not considered that the loss of about 1.34hectares of agricultural land which supports biota common on agricultural land to enable this development is justified, given that the area is not zoned for development.
7.5.4 Overall, it is considered that the proposal would be unnecessary and averse to the requirements of Environment Policies 1 and 4 of the Strategic Plan.
7.7 HIGHWAY SAFETY (TP1 AND TP4) 7.7.1 With regard to highway impacts, it is considered that the site is situated along a main bus route for public transport to the north and south of the Island, as well as good connections throughout the Island. Furthermore, there would be no changes to the site access which offers good visibility onto the main highway, and these are considered as positive elements of the scheme which aligns with Transport Policy 1.
7.7.2 Similarly, DOI Highway Services have not opposed the application as they find it to have no significant negative impact upon highway safety, network functionality and /or parking. They however, request that if appropriate, restrictions to use should apply, particularly in relation to extent of a season, which raises concerns as to the potential for greater impacts on the highway network given that restrictions on extent of season would be inapplicable in this case, considering the proposal is for the permanent use of the field as a campsite.
7.7.3 It would be vital to note that there remains a planning concerns for the lack of information and detail provided as part of the application to demonstrate that the existing access can cope with the volume of traffic expected from the extension of camping activities into the field. As well, there is no information on traffic surveys and parking surveys to demonstrate that the proposal would not result in an intensification of use beyond the capacity of the existing parking provisions within the broader site area or that the development would not exacerbate highway safety concerns at the main junction providing access onto the Mountain Road. This is particularly relevant as the proposal is expected to generate an increased level of traffic to and from the site due to its scale of operations which would be considerably at variance with the current agricultural use of the site, and this has highway ramifications.
7.7.4 Therefore, it is considered that although the scheme would align with the provisions of Transport Policy 1 due to its proximity to existing public transport facilities and routes, insufficient information has been provided to support that the proposed development would not result in adverse impacts on parking and highway safety for the site and surrounding highways, and as such the development is considered to be contrary to Transport Policy 4 of the Strategic Plan.
8.0 CONCLUSION 8.1 Overall, it is considered that there is no information provided to demonstrate that there are no other reasonably acceptable alternatives or that there is an overriding national need for a campsite of this standard in this specific location. Also, the development would result in a significant culmination and spread of camping items and supporting facilities on land which is not designated for development and which would adversely impact the visual appearance of the site and surrounding countryside. Moreover, it has not been demonstrated that the proposed use and the expected increase in traffic at the site can be suitably accommodated without detriment to parking and highway safety of the area. Furthermore, the application is not supported by an EIA which should have been provided considering the proposal is for a permanent use of land not designated for development for a campsite. The scheme is also considered to result in unacceptable loss of an agricultural site without overriding need or alternatives being demonstrated.
8.2 Based on the foregoing, the proposal is considered to fail the requirements of Strategic Policy 8, Transport Policy 4, Environment Policies 1 and 24, and General Policy 3 of the
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Strategic Plan. The scheme is also considered to be contrary to the principles of the Department for Enterprise IOM Destination Management Plan 2016-2020 and Non-Serviced Accommodation Futures Study (March 2017).
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: 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 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:...22.05.2023
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
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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23/00126/C Page 13 of 13
PLANNING COMMITTEE DECISION 22.05.2023
Application No 23/00126/C Applicant Mrs Fiona Cregeen Proposal Use of Field 534492 for camping purposes (retrospective) Site Address Field Number 534492 Glen Dhoo Hillberry Onchan IM4 5BJ Planning Officer Mr Paul Visigah Presenting Officer As above Addendum to the Officer Report
The Planning Committee considered the application at its meeting on 22 May 2023 and agreed with the recommendation to refuse the application subject to the officer's amendment to delete the fifth reason for refusal which related to Highway issues.
The reason to be deleted states thus:
R5: Transport Impacts It has not been fully demonstrated that the proposal and the expected increase in traffic at the site can be suitably accommodated without detriment or harm to the highway safety of the area, contrary to Transport Policy 4.
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