**Document:** APL Statement **Application:** 24/00474/B — Erection of 2No Dwellings, alteration to existing vehicular access, and erection of replacement boundary wall (retrospective) to rear south boundary **Decision:** Permitted **Decision Date:** 2025-02-14 **Parish:** Lezayre **Document Type:** report / planning_statement **Source:** https://planningportal.im/a/32323-lezayre-land-to-rear-replacement-alteration/documents/1061171 --- # APL Statement ## Planning Statement To Support An Application For The Erection Of Two Dwellings With Details Of Access, Drainage And Landscaping At The Auburns, Lezayre Road, Ramsey ![A street-level photograph showing the front elevation of a large, two-story cream-colored detached house behind a black metal gate and grey boundary wall.](https://images.planningportal.im/2024/04/7082189.jpg) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 1.0 Introduction - 1.1 The Auburns is a detached building which sits on the southern side of Lezayre Road (A3 TT Course) between Parliament Square and Bircham Avenue. - 1.2 The existing dwelling on the site, The Auburns, sits slightly off centre within the plot, to the south west, and towards the front of the plot, observing the building line of the terraces to the north east and south west. The Auburns sits slightly further back than these adjacent buildings, with 7.5m between the frontage of the building and the back of the footpath, with the terrace to the north east being between 6-6.5 from the highway and Altdale Terrace to the south west being closer, at around 4m from the highway. Between The Auburns and Altdale Terrace, sits The Oaks, a much newer dwelling which sits at an angle to the highway and slightly further back than is The Auburns. - 1.3 Also within the site is a stone outbuilding which sits to the rear of the house. This is Lshaped and two storeys in height. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![An aerial photograph showing a residential area with visible street names including Lezayre Rd and the A3, serving as a location map for the site.](https://images.planningportal.im/2024/04/7082191.png) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A photograph showing a stone outbuilding covered in ivy with a person inspecting the wall and a work van parked on a gravel driveway.](https://images.planningportal.im/2024/04/7082193.jpg) ![A photograph of a large, weathered stone barn or agricultural building with a slate roof and wooden doors. Construction materials are visible on the gravel yard in front, indicating renovation work.](https://images.planningportal.im/2024/04/7082194.jpg) 1.4 Both The Auburns (albeit in a different format - with different rear annexes) and the outbuilding appear on the 1860s County Series mapping and appear to mark the western extent of Ramsey at this time: Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![photograph from page 4](https://images.planningportal.im/2024/04/7082196.jpg) ![map or plan from page 4](https://images.planningportal.im/2024/04/7082197.png) 1.5 Vehicular access into the property exists via a driveway which sits to the north east of the house although there is pedestrian access directly in front of the house. The driveway runs along the north western side of the house, past some mature, tall trees and there is car parking space between the rear of the house and the outbuilding. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A photograph showing a gravel driveway area adjacent to an old stone building covered in ivy, with a wooden fence and hills in the background.](https://images.planningportal.im/2024/04/7082199.jpg) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A photograph showing a gravel courtyard or driveway area with stone buildings on the left and rear, set in a rural environment.](https://images.planningportal.im/2024/04/7082201.jpg) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A photograph showing a gravel driveway running alongside a concrete boundary wall with trees and hills in the background.](https://images.planningportal.im/2024/04/7082203.jpg) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A photograph showing a gravel driveway leading up to a detached yellow house with a dark roof. A white car is parked on the left and a large tree stands on the right side of the frame.](https://images.planningportal.im/2024/04/7082205.jpg) - 1.6 The house has long been used as two dwellings with one front entrance door which divides into two in the foyer, leading to two separate units of accommodation. Each has separate services. - 1.7 The watercourse, Strooan ny Crawe runs to the rear of the property from Ramsey Golf Course to discharge into the harbour. This watercourse becomes culverted at the north eastern corner of the Lheighany Playing Fields. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 2.0 Planning status - 2.1 The site lies within an area designated on the Ramsey Local Plan of 1998 as Predominantly Residential. - 2.2 One of the trees on the site was recently (22.2.22) Registered (RT1173). There are no Registered Buildings on the site and it does not lie within a proposed or adopted Conservation Area. - 2.3 The land to the rear of the house lies within an area at high risk of tidal and river flooding on the national flood risk mapping: Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ![A map extract showing the site location with red boundary lines and surrounding residential properties.](https://images.planningportal.im/2024/04/7082208.png) ## 2.4 Area Plan for the north and west ![map or plan from page 11](https://images.planningportal.im/2024/04/7082211.png) - 2.4.1 The Cabinet Office is in the process of preparing an Area Plan for the north and west of the Island which includes Ramsey and will ultimately replace the Ramsey Local Plan and all of the other local plans and the Isle of Man Planning Scheme (Development Plan) Order 1982 for the study area. This Area Plan is in relatively stages of preparation but a draft Plan and modified draft plan have been published with a public inquiry announced to start on 16th July, 2024. The site continues to sit within an area designated as Predominantly Residential on the Proposals Map. - 2.4.2 The Environmental Constraints map accompanying the draft Area Plan does not identify any constraints appertaining to this site: the infrastructural constraints map identifies part of the site (including the existing house, outbuilding and all of the rear of the plot) and the land to the east and south as of high risk of tidal flooding but not tidal and river flooding as was noted in the earlier flood risk information (see above). ### 2.5 Strategic Plan2.5.1 The Strategic Plan is based upon the principles of sustainable development where newbuilding is directed towards existing settlements and where optimisation of the use of land isencouraged: Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C Strategic Aim: To plan for the efficient and effective provision of services and infrastructure and to direct and control development and the use of land to meet the community’s needs, having particular regard to the principles of sustainability whilst at the same time preserving, protecting, and improving the quality of the environment, having particular regard to our uniquely Manx natural, wildlife, cultural and built heritage. - Strategic Policy 1: 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 reusing 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. - Strategic Policy 2: New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(2) of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3. Spatial Policy 2: Outside Douglas development will be concentrated on the following Service Centres to provide regeneration and choice of location for housing, employment and services…Ramsey… Area Plans will define the development boundaries of such centres so as to provide a range of housing and employment opportunities at a scale appropriate to the settlement. Spatial Policy 5: New development will be located within the defined settlements. Development will only be permitted in the countryside in accordance with General Policy 3. Housing Policy 4: New housing will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(1) of these towns and villages where identified in adopted Area Plans: otherwise new Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C housing will be permitted in the countryside only in the following exceptional circumstances: - (a) essential housing for agricultural workers in accordance with Housing Policies 7, 8, 9 and 10; - (b) conversion of redundant rural buildings in accordance with Housing Policy 11; and - (c) the replacement of existing rural dwellings and abandoned dwellings in accordance with Housing Policies 12, 13 and 14. 2.5.2 There are also policies which provide guidance on new development: - 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. - 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; and (c) not cause or lead to unacceptable environmental pollution or disturbance. - 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. 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. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C General Policy 2: Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development: - (a) is in accordance with the design brief in the Area Plan where there is such a brief; - (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them; - (c) does not affect adversely the character of the surrounding landscape or townscape; - (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses; - (e) does not affect adversely public views of the sea; - (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks; - (g) does not affect adversely the amenity of local residents or the character of the locality; - (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space; - (i) does not have an unacceptable effect on road safety or traffic flows on the local highways; - (j) can be provided with all necessary services; - (k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan; - (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding; - (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and - (n) is designed having due regard to best practice in reducing energy consumption. Housing Policy 6: Development of land which is zoned for residential development must be undertaken in accordance with the brief in the relevant area plan, or, in the absence of a brief, in accordance with the criteria in paragraph 6.2 of this Plan. Briefs will encourage good and innovative design, and will not be needlessly prescriptive. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C Recreation Policy 3: Where appropriate, new development should include the provision of landscaped amenity areas as an integral part of the design. New residential development of ten or more dwellings must make provision for recreational and amenity space in accordance with the standards specified in Appendix 6 to the Plan. Transport Policy 1: New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes. 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. Transport Policy 7: The Department will require that in all new development, parking provision must be in accordance with the Department’s current standards. Typical residential standard is 2 spaces per unit, at least one of which is retained within the curtilage and behind the front of the dwelling. 2.5.3 Policies which provide caution over certain sensitive elements of the townscape are as follows: 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; Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - (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. Some areas to which this policy applies are identified as Areas of Ecological Importance or Interest on extant Local or Area Plans, but others, whose importance was not evident at the time of the adoption of the relevant Local or Area Plan, are not, particularly where that plan has been in place for many years. In these circumstances, the Department will seek site specific advice from the Department of Agriculture, Fisheries and Forestry if development proposals are brought forward. Environment Policy 10: Where development is proposed on any site where in the opinion of the Department of Local Government and the Environment there is a potential risk of flooding, a flood risk assessment and details of proposed mitigation measures must accompany any application for planning permission. The requirements for a flood risk assessment are set out in Appendix 4. Environment Policy 13: Development which would result in an unacceptable risk from flooding, either on or off-site, will not be permitted. Environment Policy 42: 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. Inappropriate backland development, and the removal of open or green spaces which contribute to the visual amenity and sense of place of a particular area will not be permitted. Those open or green spaces which are to be preserved will be identified in Area Plans. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 2.6 Ramsey Local Plan Written Statement - 2.6.1 As well as providing a land use designation map, there is also a Written Statement which accompanies the maps of the adopted Ramsey local Plan and which provides supplementary information to guide new development. The following is considered relevant although in principle there is an inherent challenge to reconcile this with Strategic Policy 1 and perhaps Environment Policy 42 is a more appropriate policy to consider in the matter of backland development: Policy R/R/P3: Infill/Backland sites Within areas zoned for Predominantly Residential use there will be a general presumption against the development of those sites which provide attractive, natural “breathing”spaces between established residential buildings. These sites will often include trees, mature landscaping or simple green space. Any possible development of such sites should form the subject of consultation with the Office of Planning prior to the submission of any application. Policy R/E/P3: Backland Development and Development in the Grounds of Houses There shall be a general presumption against backland development and development within the grounds of large houses on those sites which are well landscaped within [sic] ample tree coverage. 2.7 Manual for Manx Roads - 2.7.1 This document sets out standards and guidance on new development in respect of new roads, accesses, visibility splays and car parking. It is intended to supplement, not replace the standards within the Strategic Plan and its contents should be taken into account in the design of new residential development. 2.8 Residential Design Guidance (RDG) - 2.8.1 This provides guidance on the design of new housing as well as clarification on how the impact of new development will affect the living conditions of those in adjacent dwellings. It also refers to Design Statements, suggesting that: a design statement provides an opportunity for the applicant to explain how they have considered a Sustainable Construction approach (see Chapter 2.0) Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C responded to the need to: maximise carbon sequestration; minimise greenhouse gas emissions; maintain and enhance ecosystems; achieve biodiversity net gain; provide sustainable drainage systems; and provide active travel and public transport infrastructure - 2.8.2 There is a whole section on sustainable construction and any application needs to demonstrate what has been taken into account in this respect in the design and layout. - 2.8.3 It also refers to environmental enhancement encouraging development to result in a net gain in biodiversity and the creation of “pleasant, healthy, safe and inclusive spaces”. It encourages “local distinctiveness” and good quality design which respects the nature of the development site and the character of the neighbouring buildings and surrounding area. The Design Statement should explain how the development complies with this. - 2.8.4 It helpfully reinforces the desire for optimising the use of unused and under-used land, stating that the change of use of Greenfield land to developed can significantly contribute to greenhouse gas emissions, preferring the development of brownfield land but warning that developments should be fit for purpose. It refers to town centre development having a density of 40-100 houses per hectare (high) and where this is typically terraced or apartment housing. Sites close to the settlement centre including apartments and terraced housing being 15-30 houses per hectare and “large sites towards the edge of settlements” being 5-10 dwellings per hectare. It specifically says that “it is important to facilitate development which allows the reuse of previously developed land and/or the reuse of these buildings (paragraph 3.7.2) adding, “it is acknowledged that sometimes a pragmatic approach may need to be taken in applying policies and standards to enable this reuse to occur” (paragraph 3.7.2). - 2.8.5 Sections 4 and 7 discuss the 45 degree and 25 degree approach to assessing the impact of new buildings on the outlook and privacy of those in neighbouring properties. The application should demonstrate how these standards are met. These standards will need to be met within the development as well as in terms of those houses alongside the site. 2.9 General planning guidance 2.9.1 Newly issued planning guidance focuses on the need for sustainable construction and clarification of how this will be achieved in any new development. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 3.0 Planning History - 3.1 The site has been the subject of the following applications: - 88/01273/A - approval in principle for dwelling and garage, to the rear of The Auburns approved - 89/01975/A approval in principle for the erection of dwelling with garage, to the rear of The Auburns - refused 03/00669/A - approval in principle for the erection of dwelling and garage - approved - 06/01369/REM - reserved matters application for the erection of dwelling and garage approved: this included a flood bund at the rear which has been constructed and is in situ - 07/01058/B - alterations and conversion of barn to a dwelling - approved 19/00778/B - conversion and extension of barn to create a residential dwelling - approved and expired on 07.10.23 - 22/01212 - approval in principle for residential development (illustrative layout of four plots) with access detailed and all other matters reserved - refused on 17.10.23. The three reasons for refusal related to the consideration that inadequate information had been provided to demonstrate that the occupants of the proposed development and the surrounding area would not be at unacceptable risk of flooding, and that the layout of the proposed development could result in a significant loss of an established green corridor which has public amenity value. - 23/00306/B - extension of time for 19/00778/B which now expires on 28.07.25 23/00490/B - alterations, replacement of rear extension and front porch and raising of roof to provide additional living accommodation , The Auburns - refused on 06.03.24 for reasons relating to potential adverse impact on the adjacent Registered Tree, and the adverse impact of the proposals on the architectural interest of the existing building. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 4.0 The proposal - 4.1 Proposed is the erection of two new dwellings in the area of the existing outbuilding which is to be demolished (works for which planning approval is not required) and where a further dwelling had been previously permitted together with the associated drainage, access and overall landscaping, tree protection and flood risk prevention works. - 4.2 The two dwellings would sit partly on the footprint of the existing outbuilding to be demolished and partly on the footprint of the dwelling which had planning approval, both of which are shown in blue on plan reference 22 1631 02. - 4.3 The dwellings are two storey buildings with garaging for two cars each plus a driveway which will accommodate a further two vehicles, living accommodation on the ground floor and sleeping accommodation (four bedrooms) on the first floor. - 4.4 The dwellings will be separated from each other by a new planted hedge with a fence in the centre and the buildings will be raised above existing ground level by approximately 1m to a level of 5.5. The fluvial flood level of 5.370 is shown on the proposed elevations (drawing 22 1631 07) along with the tidal flood level of 5.640 along with the top of the bund and fence line alongside the rear watercourse, at 5.700. - 4.5 The dwellings will have a single storey attached garage with dormer accommodation on top, and be finished in stone cladding and render with composite cladding on the dormer window, either side of the porch door. - 4.6 The dwellings will have their front elevation facing the other property with the two rear elevations which face towards the rear gardens of The Oaks and 17, Lezayre Road, having only a set of vertical windows which serve a bathroom and a utility room and a ground floor window serving a proposed dining area within a combined kitchen/dining/sitting room. Drainage - 4.7 Drainage will be provided, discharging foul sewage to the combined sewer in Lezayre Road (shown on the drawings) and surface water to either the nearest watercourse subject to the appropriate discharge licence or soakaways, dependent upon the nature of the ground (percolations tests undertaken have revealed that the ground is suitable for soakaways). All new hard surfacing will be a fully permeable surface system Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ## Flood risk - 4.8 A Flood Risk Assessment (FRA) is provided, prepared by Axis Consulting Engineers and dated 21.03.24 which confirms the status of the site as being at risk of flooding, noting the national flood risk maps which shows the site at high risk of tidal and fluvial flooding (see paragraph 2.4.2 above). - 4.9 It acknowledges that due to the proximity of other dwellings, it would not be unlikely to be acceptable to increase the finished floor level of the proposed dwellings to exceed the modelled tidal flood events and as such, the proposal to raise the proposed FFL to 5.50m AOD which would achieve a nominal freeboard of 130mm against the fluvial flood level is considered reasonable with other measures to address the modelled tidal flood levels to achieve a 600mm freeboard against the 0.5% annual exceedance probability event (plus climate change). These measures include the raising of the embankment bund to 600mm to allow a 300,, above the fluvial event, the introduction of flood boards to all openings to a height of 0.8m. - 4.10 It is noted that tidal flooding can involve some level of future prediction and thus sufficient notice to the occupant to implement to protection measures and given the location well within a built up area which is also within the same area of risk, it is expected that there would be wide scale public warnings ahead of the event (as occurs at present). - 4.11 All sockets, switch boards, fuse boxes and electrical outlets be raised to 0.8m above FFL and all sleeping accommodation (the most vulnerable rooms) are at first floor level. - 4.12 In addition, to help mitigate the loss of existing permeable areas, no hardstanding will be put in place for driveways or landscaping and a fully permeable surface will be installed to minimise surface water run off using infiltration. - 4.13 It also recommends that a flood evacuation plan should be put in place. - 4.14 The FRA concludes that the proposed measures referred to above will result in a low risk of damage to property and low risk to occupants from flooding. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C ## Access - 4.15 Access to the new properties will utilise the existing access which has available to it, visibility splays onto Lezayre Road of 2.4m by 55m to the south west and 2.4m by 43m to the north east. - 4.16 The works propose to widen the entrance to enhance visibility and manoeuvring space for vehicles entering and leaving the site and also to accommodate space for refuse bins to be kept on collection day: they will not be stored there permanently. None of these works will involve the Root Protection Area (RPA) of any adjacent tree. Biodiversity enhancement - 4.17 The applicants will contact the Manx Bat Group prior to the demolition of the barn to ensure that there is no harm to this protected species and will ensure that there are no nesting birds, in compliance with the Wildlife Act 1990 although it should be noted that planning approval is not required for the demolition of the building. - 4.18 There is also the opportunity for the introduction of local flora which support biodiversity as replacements for those trees which need to be removed due to their presently health. Tree protection - 4.19 A tree report is provided in the acknowledgment of the registered status of one of the existing trees on the site and the importance, generally, of trying to retain existing trees of amenity value. RPAs are shown for all of the existing trees on site and the majority will be retained although it should be noted, as stated in the Tree Report, that many of these are ash and are suffering from ash dieback and their longer term future is not secure and indeed they need to be removed (17 ash trees and a further sycamore and holly which are also in poor condition) and would benefit from being removed, irrespective of any development proposals. The development can be undertaken without the need for the removal of any trees of amenity value and which are healthy and trees, particularly those on the boundary with other residential property may be retained as long as is practical and replaced if not and there will be no additional works in the RPA of any of the trees. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 5.0 Conclusion - 5.1 The site is designated for residential development and is highly sustainable - close to the town centre and sustainable modes of transport so the principle of the development of more dwellings on this site should be considered to be in accordance with the sustainability policies identified above and the newly emerging Area Plan for the North and West. - 5.2 The potential constraints on development include concern about the loss of the existing outbuildings, flood risk, highway safety, impact on trees and ecology and impact on the living conditions of those in neighbouring properties. It is highly relevant in the consideration of all of these issues, that planning approval has been granted previously (and both remain capable of implementation) for additional development on this site. What is proposed does not increase the density of this additional approved development and we believe what is proposed is more supportive of the policies which support optimising the use of sustainable and under-used sites. Indeed the approved scheme for the introduction of a new dwelling in the same area as the proposed dwellings, had no flood protection incorporated into its design. - 5.3 The flood risk to the site at present has already been mitigated by new bund at the rear which will prevent floodwater from the watercourse coming into the site and this is to be increased in height, increasing its efficacy. From the front, mitigating the ingress of flood water from Lezayre Road, as shown as being a risk on the national flood risk maps can be undertaken locally by the use of sand bags or other temporary measures as do other properties along Lezayre Road although as stated above, the proposed properties will raised in level appropriate to the predicted flood level. - 5.4 The dwellings will be built at a level to mitigate against any damage from fluvial flooding and with the incorporation of flood measures within the properties this should result in there being low, or no risk to the occupants of the properties in the event of tidal flood events to the maximum predicted level. - 5.5 Highway safety is not considered to be an issue given the planning history of the site and is demonstrated in the submitted plans that that a safe means of access is available and sufficient width of internal roads for the turning and access of the vehicles which will use the site including passing places. Bins may be stored temporarily (on collection days) at the entrance so that refuse vehicles need not enter the site. Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C - 5.6 The development will not adversely affect any trees of amenity value and new landscaping will be introduced as part of the development and could demonstrate no negative biodiversity net effect. - 5.7 The dwellings have been designed to have a unique and attractive style but whose construction utilises materials and form which is complementary to the area and avoids the introduction of windows which would result in any unacceptable overlooking of adjacent properties. - 5.8 Unacceptable backland development is presumed against but in this case, we would suggest that whilst the new housing is to be built to the rear of the existing dwellings in The Auburns, the access is to the side and there is ample separation between the rear of The Auburns and the closest part of any of the new houses to protect the amenities of all and sensitivity and the guidance in the RDG has been observed in terms of the placement of windows which look towards existing adjacent property. - 5.8 In addition, it is relevant that planning approval has been granted (and remain capable of implementation) for the creation of new housing to the rear through the conversion of the existing barn and also the erection of a completely new dwelling approval for which we believe has been commenced through the construction of the flood bund. This current proposal optimises the use of the site through no increase in density. - 5.9 It is important to remember this also in the reference in the refusal of the approval in principle for four dwellings which included a reason relating to the alleged important green corridor within the site. It would not appear that this “green corridor” has been highlighted in any published document for ecological value and cannot be publicly seen. - 5.10 As such, we struggle to understand how the development of this site could be considered unacceptable in this respect and particularly as permission has been granted, and is still capable of being implemented, for a dwelling in roughly the same position as what is now proposed. - 5.9 It is considered that the proposed development optimises the use of this highly sustainable site whilst providing a development which provides satisfactory amenities for the occupants of the proposed dwellings and whilst not adversely affecting the amenities of those in adjacent property and without adversely affecting the character and contribution Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C The Auburns makes to the streetscene, in full accordance with all of the relevant policies listed above. ## Sarah Corlett 16.04.24 Sarah Corlett Town Planning Consultancy Ltd Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett Company Registration 134325C --- *Data sourced from the Isle of Man public planning register under the [Isle of Man Open Government Licence](https://www.gov.im/about-this-site/open-government-licence/).* *Canonical page: https://planningportal.im/a/32323-lezayre-land-to-rear-replacement-alteration/documents/1061171*