**Document:** APL Planning Statement
**Application:** 24/00483/B — Erection of two agricultural shelters (retrospective)
**Decision:** Permitted
**Decision Date:** 2024-09-11
**Parish:** Lezayre
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/32360-lezayre-dhoon-loop-road-two-agricultural-shelters-retrospective/documents/1061544

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# APL Planning Statement

## Island Land-Based Services Limited

24/00483

Fields: 622432 and 622435 Dhoon Loop Road, Dhoon, Ramsey, Isle of Man IM7 1HP

Planning application for two field stable/shelters

### Introduction

The retrospective planning application is for two field stable/shelters to be used exclusively for the agricultural business on farmland owned by the applicant Mr Steven Lace located to the east of the Dhoon Loop Road, Dhoon, Ramsey. This report is to explain why the field stable/shelters are essential for the agriculture business and that they do constitute an exception to warrant the setting aside of established planning policy aimed at protecting the countryside from unwarranted development.

### The Applicant

Mr Steven Lace comes from a farming family and even though from an early age had a real interest in the agricultural industry took the decision for family and financial reasons to embark in a career in the auto industry. Having worked incredibly hard to establish a well-respected and successful business in Douglas he has sold the business and so now he can go back to his roots of farming the land which has been in his family for many years.

### The Farm

The land which Mr Lace owns is made up of a block of 11 fields totalling some 25 acres of agricultural land. The land is Grade 3 agricultural land, classified as having the potential for mixed livestock and cropping agriculture.

The land was rented out but has now been taken back 'in hand' by Mr Lace. He currently owns 50 ewes which are on the farm and with improvements to the fencing, drainage, soil health and grassland will over time be able to increase the stocking rates. He has already put in a substantial length of new stock fencing where needed, improved field drainage, cleared some areas of thick gorse and improved the biodiversity of the farm by planting trees, wildflower mixes etc. He has a flock number provided by DEFA for the sheep he owns.

Most of the agricultural machinery which he currently owns for managing the farm include a Massey Ferguson tractor, fertiliser spreader, mobile sheep handling system, fencing equipment and other general maintenance machinery is currently must be stored off-site.

As the agricultural land is gradually improved, Mr Lace will have the opportunity to look at diversifying into other agricultural enterprises to improve the economic viability of the farm. He is currently looking at investing in different breeds of sheep with the intention of setting up a small pedigree flock. Obviously, prior to investing in any other agricultural enterprises, consideration will be given to its effect on the wildlife, visual impact, current legislation and local demand for products.

### The field stable/shelters

There are no buildings currently associated with the land.

The retrospective planning application is for two 7.37m x 3.63m x 2.15m high (to the eaves) field stable/shelters which are required to ensure all necessary legislation and agricultural codes of practice can be adhered to in order that Mr Lace can farm the land. The stable/shelters are general purpose, providing storage for livestock feed and minerals, a locked veterinary medicine cabinet and storage for small agricultural machinery and tools required for running a sheep farm. They can also provide areas for lambing in poor weather and penning for individual sheep when isolation is required.

22 APR 2024

DEPT OF ENVIRONMENT

DOID AND MARKETING

## Location

The field stable/shelters are located towards in the north-west corner of Field: 622432 and the north-west corner of Field: 622435 . The visual impact has been carefully considered and the locations are not liable to flooding. The one in Field: 622432 is close to the trees between the boundary fence and the electric tram but as no foundations were required the trees will not be affected. The one in Field: 622435 is hidden by the boundary hedge.

### Reasons for refusal for the proposed agricultural building in Field: 622432 and for the field shelter/stable.

The reasons for refusal of the proposed agricultural building in Field: 622432 (PA/00802/B) were:

- R 1. There is not an existing agricultural business extant on this smallholding sufficient to justify the erection of a steel frame building. Therefore, such a development would be contrary to the requirements of General Policy 3 and Environment Policy 15 of the Isle of Man Strategic Plan 2016 which require that the Department be satisfied that there is agricultural or horticultural need for a new building sufficient to outweigh the general policy against development in the countryside.
- R 2. The site is located within an Area of High Landscape or Coastal Value and Scenic Significance. The steel framed building as proposed would be an isolated and incongruous feature positioned in an elevated field of steep gradient within the open countryside within a sensitive landscape. The proposal would not be amenable to screening and result in an unacceptable level of detriment to the character and visual amenity to the surrounding Area of High Landscape or Coastal Value and Scenic Significance. Such development would be contrary to Environment Policy 2 and General Policy 3 of the Island Wide Strategic Plan 2016.

The overall inspector's conclusions at appeal were:

- The proposed building would be appropriately located within the 26-acre appeal site if it were justified by genuine agricultural need. However, there is insufficient evidence of such agricultural need, beyond the mere aspiration and preference of the Appellant for built accommodation onsite.
- Some weight is to be accorded to the broad encouragement given to new agricultural enterprise on the Island and the Minister is entitled to judge that the available evidence of agricultural need is, in the circumstances, sufficient to satisfy the requirement of EP15 and justify approval.
- However, it is my own conclusion, on balance overall, that the proposal would be in overriding conflict with the protective measures of GP3 and EP1-2 of the IMSP for the landscape of the countryside within the designated the AHLV and that, accordingly, the appeal should fail.

The reason for refusal of the installation of a field/stable (retrospective) in fields adjacent to Dhoon Loop Road (PA/22/00690/B):

- R 1. It is not considered that there is sufficient agricultural need for the shelter to outweigh presumption against development here, or to over-ride the harm to the character and appearance of the countryside. The development is therefore considered to be contrary to Environment Policies 1, 2, 15 and 21 of the Strategic Plan.

The overall main two reasons for refusal are 1. Insufficient agricultural need 2. The area is within an Area of High Landscape or Coastal Value and Scenic Significance.

## Justification for the two field stable/shelters

### 1. Stocking rates, farm profitability and standard labour units

Mr Lace now has the time to develop his agricultural business and in so doing enhance the business profitability whilst maintaining the wildlife biodiversity of the farm. The plan is not to increase the number of ewes to 100 as detailed in the Inspectors report for PA/00802/B as maximising stocking may result in overstocking during times of drought or other severe weather conditions but slowly increase ewe numbers to a maximum of 70 and to also purchase store lambs and then sell them to Isle of Man Meats as finished lambs. This plan would therefore allow some flexibility to the farming business and avoid over or undergrazing. The farm budgets for the next four years (Table 1) show the number of purchased store lambs increasing from 75 in year two to 125 in year 4. However, without somewhere to store supplementary minerals, concentrates and veterinary medicines in a secure location on the farm, the business will be unable to develop and purchase store lambs.

With the field stable/shelters the budgets indicate that initially the business can make a small profit but with increasing number of store lambs the farm will start to become a viable unit. The profitability could be increased further with the introduction of pedigree sheep breeds and the selling of ewe and ram lambs for breeding. This however is not a practical proposition without the ability to store materials or have somewhere which can be used for newly born lambs which need additional help especially if the weather at lambing is cold and wet.

The standard labour requirements have also been calculated. The current system requires just 0.29 standard man hours/year (Table 2) but with the increased number of ewes and the purchase of store lambs this would increase to 0.63 (Table 3).

There was a comment from the owners/occupiers of Thalloo Mitchell saying that "the land has been successfully used for sheep grazing by other parties for many years, including animal welfare, without the need for such mobile development". The other parties who are referred to in the comment will be other farmers who have their farm buildings and would been able to use them for the sheep grazing on the fields owned by Mr Lace, but these cannot be used for Mr Lace's own farming business.

### 2. Farm Assurance

One of the requirements of selling finished lambs is that farms must be "Farm Assured". The following are some of the standards which are required to become farm assured:

- Facilities as appropriate must be provided when necessary for the segregation/isolation and the care of sick or injured animals.
- All medicines must be kept in a secure locked store and in accordance with the manufacturer's instructions.
- Appropriate biosecurity measures must be planned and implemented to minimise the spread of disease within the farm and between other farms.
- All feed must be readily identifiable and stored in clean conditions to prevent any form of contamination.
- An effective control system must be in operation in the areas detailed to control infestation by vermin and other animals.
- Where necessary, there must be appropriate facilities for stock to give birth. This includes clean, dry bedding, adequate lighting to allow close inspection and provision of assistance if required.
- In the interests of security, fertiliser must be stored in such a way as to reduce the risk of theft.
- All paints, preservatives, disinfectants, baits, lubricants and other chemical products must be kept in a suitable store to prevent contamination and pollution.

### 3. Welfare Code for Sheep

In addition to Farm Assurance standards, sheep producers must adhere to DEFA's Welfare Code for Sheep which is based on the five freedoms. The recommendations in the Code help producers meet the requirements of the Animal Health Act and Welfare of Farm Animals Order.

The following are the recommendations in the Code which would be very difficult to adhere to without housing:

- Sheep should be provided with fresh feed, and any which is stale or contaminated should be removed from troughs before more is added.
- Feed should be palatable and of good quality.
- Arrangements should be made in advance to ensure that adequate supplies of suitable feed and water can be made available to sheep in emergencies, such as severe winter storms or summer drought.
- Provision should be made, and used, when necessary, for the segregation and care of sick or injured animals.
- All sheep farmers should have easily operated and efficient handling pens, to facilitate routine management and treatment, on a size and scale to suit the flock numbers.
- A source of heat (for example a warmer box) should be available to revive weak lambs, but care should be taken to avoid overheating.
- For artificial rearing: A dry bed and adequate draught-free ventilation should be provided and where necessary, arrangements should be made to supply safe supplementary heating for very young lambs. Suitable accommodation should be available for sick or injured lambs. This should be separate from other livestock.

### 4. Biosecurity

To ensure biosecurity is maximised requires farmers having the ability to isolate sheep that are brought onto the farm for a period to ensure they are not suffering or are carriers of any diseases as well as facilities for segregating sick animals.

### 5. Farmyard Manure

The very small amount of farmyard manure which may be produced from having livestock in the field stable/shelters would be put back onto the land and thereby improving soil fertility and organic matter.

### Area of High Landscape or Coastal Value and Scenic Significance

The site of the field stable/shelters has been carefully located and is well screened from the public highway and tramline by the area of woodland. It is not even visible from the driveway to Thallo Mitchell as the land dips away towards the northern field boundary and will be screened even further as more trees are planted.

### Planning Application PA 21/00727/B

The planning officer who assessed PA22/00690/B partly justified his decision based on DEFA's Head of Agriculture's assessment of PA 21/00727/B. "There is no Agricultural/welfare need to house sheep in bad weather. In fact, the opposite is the case - sheep are 'designed' to live outdoors in all weathers. Whilst housing machinery does prolong its life, owning machinery to manage a holding of this size is a luxury rather than a need. It is far better to contract in to get work done. There is no need to have covered area for conducting health checks".

This application is very different to PA 21/00727/B in the fact that the field stable/shelters are not going to be used to house all the sheep in bad weather but to have an area which can be used for individual sheep which need to be isolated for veterinary treatment or for lambs who need extra support during their first few days of life. Application PA22/00690/B is associated with a much smaller area of land and only 13 ewes at the time the application was submitted.

## Planning Policy

The following policies are relevant to the application:
General Policy 3: Development will not be permitted outside of those areas which are zoned for development on the appropriate Area Plan with the exception of:
(f) building and engineering operations which are essential for the conduct of agriculture or forestry;
(g) development recognised to be of overriding national need in land use planning terms and for which there is no reasonable and acceptable alternative;
Agricultural buildings are required on the Isle of Man to ensure that animal welfare standards are maintained, and equipment and materials are stored securely. A planning application was submitted by the applicant on 1st August 2018 for a purpose-built permanent building which was refused at appeal. Although the field stable/shelters will not enable the farming business to grow as anticipated, it will ensure that the farm can be managed in a safe and secure way.

Environment Policy 1: The countryside and its ecology will be protected for its own sake. For the purposes of this policy, the countryside comprises all land which is outside the settlements defined in Appendix 3 at A.3.6 or which is not designated for future development on an Area Plan. Development which would adversely affect the countryside will not be permitted unless there is an over-riding national need in land use planning terms which outweighs the requirement to protect these areas and for which there is no reasonable and acceptable alternative.
The Isle of Man government is committed to growing the food industry (Food Matters: A development strategy to grow the economic contribution of Isle of Man Food and Drink from 2015 to 2025) and the government also has a policy to encourage the effective utilisation of the Island's land and sea resources by the most efficient means to secure the optimum economic benefits, whilst having due regard to biodiversity, sustainability, climate change and energy issues facing the Island
(https://www.gov.im/about-the-government/departments/environment-food-and-agriculture/policy-enforcement-and-data-searches/).

Environment Policy 2: The present system of landscape classification of Areas of High Landscape or Coastal Value and Scenic Significance (AHLV's) as shown on the 1982 Development Plan and subsequent Local and Area Plans will be used as a basis for development control until such time as it is superseded by a landscape classification which will introduce different categories of landscape and policies and guidance for control therein. Within these areas the protection of the character of the landscape will be the most important consideration unless it can be shown that:
(a) the development would not harm the character and quality of the landscape; or
(b) the location for the development is essential

The stable/field shelters are located in such a place to ensure that the character and quality of the landscape is not inadvertently affected.

Environmental Policy 15: Where the Department is satisfied that there is agricultural or horticultural need for a new building, sufficient to outweigh the general policy against development in the countryside, and that the impact of this development including buildings, accesses, servicing etc. is acceptable, such development must be sited as close as is practically possible to existing building groups and be appropriate in terms of scale, materials, colour, siting and form to ensure that all new developments are sympathetic to the landscape and built environment of which they will form a part.
Only in exceptional circumstances will buildings be permitted in exposed or isolated areas or close to public highways and in all such cases will be subject to appropriate landscaping. The nature and construction must also be appropriate to the purposes for which it is intended.

Where new agricultural buildings are proposed next to or close to existing residential properties, care must be taken to ensure that there is no unacceptable adverse impact through any activity, although it must be borne in mind that many farming activities require buildings which are best sited, in landscape terms, close to existing building groups in the rural landscape.
There are no other buildings or dwelling associated with the land and although to fulfil Policy 15 the field stable/shelters should be located adjacent to the properties Thalloo Mitchell or Thalloo-Ree, it is accepted that this would not be fair to the occupants so consideration will always be given to the neighbours when they are moved to new locations on the farm.

## Planning Conditions

The applicant has indicated that he has no problem with conditions being placed on the field stable/shelters restricting their use solely for agriculture.

### Summary and Conclusion

The applicant has the ability and knowledge to run a farming business producing top quality lambs for the local market if given the opportunity. The planning application for the erection of the stable/shelters is being submitted solely to ensure that the applicant can continue farming and to manage his sheep flock in a way to ensure that all relevant codes, legislation and other agricultural standards can be adhered to as well as security for his agricultural equipment.

With the recent economic difficulties of farming on the Isle of Man and the uncertainty of the agricultural industry with Brexit, it is crucial that those who can invest in the industry are encouraged to do so for the future of the whole of the Manx Agricultural Industry.

In conclusion, there is no doubt that the field stable/shelters are essential for managing the farming business at a time when farmers must prove to government, abattoirs, retailers and consumers that they are farming to specific high standards.

## Budgeted Profit and Loss Account

### Steve Lace - Farming business

|  PERIOD ENDING 31st MARCH | 2025 | 2026 | 2027 | 2028  |
| --- | --- | --- | --- | --- |
|  Number of ewes | 50 | 50 | 60 | 70  |
|  Number of purchased store lambs/year | 0 | 75 | 100 | 125  |
|  Number of ewes/lambs retained for breeding | 3 | 14 | 15 | 5  |
|  Lambing percentage | 150% | 155% | 160% | 165%  |

### Income

|  Description | 2025 | 2026 | 2027 | 2028  |
| --- | --- | --- | --- | --- |
|  Finished lambs | 70 | 110 | 138 | 177  |
|  Coll ewes/tups | 1 | 5 | 3 | 4  |
|  Wool | 1 | 20 | 20 | 35  |
|  Subsidies | 25 | 64 | 25 | 1600  |
|  AES |  |  |  | 260  |
|  Subsidies |  |  |  | 9585  |

### Expenses

|  Description | 2025 | 2026 | 2027 | 2028  |
| --- | --- | --- | --- | --- |
|  Store lambs | 0 | 75 | 5250 | 125  |
|  Tups | 0 | 0 | 0 | 700  |
|  Concentrates & Minerals | 50 | 15 | 50 | 750  |
|  Concentrates & Minerals | 75 | 5 | 75 | 152  |
|  Vet & Med | 50 | 10 | 50 | 500  |
|  Lambs | 75 | 3 | 50 | 152  |
|  Vet & Med | 75 | 3 | 3 | 456  |
|  Forage crops | 0 | 0 | 0 | 0  |
|  Forage and bedding | 1 | 200 | 200 | 200  |
|  Fertilizers/lime | 25 | 30 | 25 | 30  |

### Overheads

|  Description | 2025 | 2026 | 2027 | 2028  |
| --- | --- | --- | --- | --- |
|  Fuel and oil | 500 | 500 | 600 | 650  |
|  Machinery repairs | 750 | 750 | 800 | 1000  |
|  Insurance | 500 | 500 | 525 | 550  |
|  Telephone | 150 | 150 | 175 | 200  |
|  General expenses | 500 | 500 | 600 | 700  |
|  Water | 400 | 400 | 450 | 500  |
|  Building repairs | 150 | 150 | 200 | 250  |
|  Fencing | 750 | 750 | 800 | 850  |
|  **Total** | 6500 | 6500 | 15568 | 18970  |

### Net Farm Profit

|  Description | 2025 | 2026 | 2027 | 2028  |
| --- | --- | --- | --- | --- |
|  Net FARM PROFIT | 3085 | 4724 | 5872 | 8980  |

assuming 5% overhead allowance

assuming 2000 standard man hours/year per labour unit

* Numbers based on 150% lambing

assuming 5% overhead allowance

assuming 2000 standard man hours/year per labour unit

* Numbers based on 165% lambing

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*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/32360-lezayre-dhoon-loop-road-two-agricultural-shelters-retrospective/documents/1061544*