**Document:** Planning Statement
**Application:** 25/90371/C — Additional use of living space above detached garage as tourist accommodation (class 3.6)
**Decision:** Permitted
**Decision Date:** 2025-08-28
**Parish:** Marown
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/34076-union-mills-ballahutchin-house-garage/documents/1085757

---

# Planning Statement

## Uplift Planning

### Where Our Plan Is Action

### Planning Statement

Additional use of the living space above a detached garage at Ballahutchin House, Ballahutchin Hill, Union Mills as tourist living accommodation (Use Class 3.6)

## This Planning Statement has been prepared by Ste Stanley, Chartered Member of the Royal Town Planning Institute

Planning Statement – Additional use of the living space above a detached garage at Ballahutchin House, Ballahutchin Hill, Union Mills as tourist living accommodation (Use Class 3.6) Introduction and Proposal Overview

This Planning Statement is submitted in support of an application for approval for the additional use of the living space above a detached garage at Ballahutchin House, Ballahutchin Hill, Union Mills as tourist living accommodation (Use Class 3.6).

A previous application was refused in October 2022. This statement addresses the reasons for refusal given in the Decision Notice and Officer’s Report, demonstrates how the proposal now complies with the Isle of Man Strategic Plan 2016 and the Area Plan for the East 2020, and highlights material changes in circumstances since the 2022 decision – notably the adoption of the Visitor Economy Strategy 2022–2032 and the Isle of Man Economic Strategy 2022. The statement also references two recent comparable planning approvals (at Lambfell Beg and Kingsley Farm) which indicate a positive approach to similar proposals, while acknowledging each case must be assessed on its own merits.

In summary, the Applicant has carefully reconsidered the proposal in light of policy requirements and new strategic priorities. The tourist use of the existing garage loft will be ancillary to Ballahutchin House – remaining within the same planning unit and not as a separate dwelling. The accommodation will be used exclusively for short-term holiday lets, secured by appropriate conditions similar to those imposed on comparable approvals. No physical extensions or external alterations (aside from any minor fit-out or safety requirements) are proposed, ensuring the rural character of the area is preserved. It is submitted that the proposal now satisfies the relevant planning policies, and that any residual concerns are outweighed by the considerable benefits of supporting the Island’s visitor economy in line with updated strategic objectives. We respectfully request that planning permission be granted for this sustainable tourism use.

## Response to Previous Reasons for Refusal

The October 2022 refusal (Ref. 22/00244/C) cited four reasons. We address each in turn, explaining how the resubmitted proposal overcomes those concerns:

Reason 1: Building Suitability for Conversion (Housing Policy 11(c) and Environment Policy 16(b)) Refusal Reason 1: “The existing building is not of any historic, social or architectural interest or of any visual attraction to warrant its conversion,” failing Housing Policy 11(c) and Environment Policy 16(b) of the Strategic Plan 2016. In other words, the original decision found that the garage loft (an existing modern outbuilding) did not meet the strict criteria for rural building conversions, which require the building to be of some inherent merit.

Applicant’s Response: We acknowledge that Strategic Plan Housing Policy 11 only permits conversion of existing rural buildings to dwellings where, inter alia, “the building is of architectural, historic, or social interest”. Likewise, Environment Policy 16 on re-use of rural buildings for new purposes (including tourist use) requires that the reuse “will result in the preservation of fabric which is of historic, architectural, or social interest or is otherwise of visual attraction”. These policies aim to prevent unsuitable structures from becoming new housing or tourist units. The previous proposal was deemed to fail these tests, as the garage is a relatively new building with no historical or cultural significance.

However, the policy wording does not strictly preclude conversion of all modern buildings – it allows some discretion if a building has other qualities such as being “of visual attraction” or if its reuse would bring benefits. In this resubmission, we emphasise the following points to demonstrate the building’s suitability:

- • High-Quality Built Fabric: The garage (constructed in 2021) is built to a high standard with a design in keeping with the main house and rural surroundings. While not historic, it possesses a high-quality appearance that is in harmony with the area. This accords with the intent of requiring an “existing built fabric of interest and quality” for tourist development proposals. The building’s solid construction and visual integration with its setting mean its conversion would preserve an attractive structure and ensure it is fully utilised. The Isle of Man Strategic Plan recognises that reusing existing buildings supports sustainability.
- • No Extensions or Material Alterations: The conversion would be entirely internal. The building is already “substantially intact and structurally capable of renovation” and is large enough to form a small one-bedroom unit. No extension is required, and there is no requirement to change the external appearance as a result of this proposal. This ensures compliance with Environment Policy 16(c), which stipulates accommodating the new use without adverse change to the building’s character. By keeping the external fabric intact, the rural character and visual quality of the building (and area) will be maintained.

In light of the above, we submit that the building does have sufficient merit and quality to justify its conversion for tourism use. It may not be a registered historic building, but it is an attractive, sound structure that would continue to visually enhance the site if sensitively used. The alternative would be a missed opportunity to support the rural economy with no tangible benefit to the countryside. This approach is supported by Strategic Policy 8, which permits tourist proposals that “make use of existing built fabric of interest and quality” without adverse impacts. We contend that this proposal meets that description. Crucially, recent planning decisions suggest the Department is prepared to accept that modern rural buildings can be put to tourist use where harm is limited – for example, the approval at Lambfell Beg (see later section) concerned a garage/office of no historic interest, yet it was judged acceptable as a small-scale tourist unit with limited harm.

Reason 2: Tourist Accommodation Policy and Overriding Need (Non-Serviced Accommodation criteria & Environment Policy 1)

Refusal Reason 2: “The proposal does not fit within or meet any of the accommodation types and high level criteria sought by the ‘Policy on the Development of Non-Serviced Accommodation’… and is not considered to be of any overriding national need as to outweigh Environment Policy 1 of the Strategic Plan 2016.” This reason reflected two concerns: (a) that the proposed tourist unit was not of a type or quality identified as desirable in the Department for Enterprise’s March 2019 Non-Serviced Accommodation Policy (a material consideration for tourism proposals), and (b) that there was no exceptional “overriding national need” to justify an exception to the general protection of the countryside under Environment Policy 1.

Applicant’s Response: We address each part: (a) Accommodation Type and Quality: The 2019 Non-Serviced Accommodation Policy (now superseded by the 2022 Visitor Economy Strategy) highlighted a focus on certain types of tourist accommodation considered to be in short supply. These included developments of multiple units, family-friendly facilities,

accessible accommodation, leisure/entertainment offerings, high-end luxury/boutique developments, clusters of units complementing tourist attractions, glamping, and group experience accommodation. The case officer assessment noted that the Ballahutchin proposal did not squarely fall into those categories – it is a single unit, not part of a larger complex, and offers no on-site leisure facilities.

While that may have been true in 2022, policy context has evolved (see the Material Changes section below). The new Visitor Economy Strategy 2022–2032 adopts a broader outlook, aiming to “widen our non-serviced accommodation supply” and encourage innovative accommodation offers across the Island. The Strategy explicitly acknowledges that “our visitor accommodation offer is lagging behind… in terms of quality and choice” and that “we need to secure investment in distinctive, contemporary and eco-friendly visitor accommodation” to attract new markets and extend the season. This indicates a material change in emphasis – every additional unit of appropriate, high-quality visitor accommodation is now seen as a positive contribution to choice and capacity, even if small in scale.

The proposal at Ballahutchin House will create a high-quality self-catering unit in a scenic location on the outskirts of a village. It will cater to visitors seeking a tranquil rural stay with easy access to the Island’s attractions (the site is centrally located, on the Douglas to Peel main road and near the Heritage Trail). This “back-to-nature” style retreat aligns with the types of distinctive accommodation the Island now seeks to support (the Visitor Economy Strategy cites demand for countryside retreats, eco-friendly units, etc., as part of an “innovative offers” portfolio). Although small, the unit will be finished and managed to a high standard, offering privacy and comfort – attributes that modern visitors (such as couples or solo travellers) often prefer over larger, multi-unit sites. We therefore submit that the proposal does meet the spirit of the current tourism strategy, which welcomes diversification of accommodation.

It is also noteworthy that the Department and Planning Committee have recently approved comparable single-unit tourist accommodation conversions (Lambfell Beg and Kingsley Farm, detailed later), implicitly accepting that such proposals can “meet with the DfE Visitor Economy Strategy” objectives when appropriately conditioned. In the Lambfell case, the Officer’s Report acknowledged the scheme “met some objectives of the ‘Our Island, Our Future’ Visitor Economy Strategy”. This resubmission provides additional detail and commitments (e.g. occupancy controls, ancillary status – see below) to ensure the proposal is recognised as a policy-compliant, well-considered tourism offering that will positively complement the Island’s visitor economy.

(b) Overriding National Need & Environment Policy 1: Environment Policy 1 of the Strategic Plan states that “the countryside… will be protected for its own sake”, and development that would “adversely affect the countryside” will not be permitted unless a proposal is of over-riding national need with no alternative, in which case it may outweigh the normal protection. The original decision judged that our proposal carried no such national-level necessity to override the presumption against countryside development.

We concur that this project is not one of national infrastructure or urgent requirement; however, we contend that invoking the “overriding need” test is unnecessary in this instance because the development will not adversely affect the countryside in the first place. The intent of Environment Policy 1 is to prevent harmful physical development (urban sprawl, landscape degradation, ecological damage) in rural areas. Here, no new building is proposed – we are utilising an existing building with no change to the external appearance or footprint. The site remains well-contained within the established residential curtilage of Ballahutchin House. There will be minimal impact on the character of the landscape: the building already exists and is visually

integrated; its use by tourists will be low-key, involving perhaps one car and the presence of short-term occupants, which is not materially different from normal residential use.

Crucially, no objections were raised by statutory or local consultees on environmental or amenity grounds during the previous application. Marown Parish Commissioners had “no objection” to the proposal, the Department of Infrastructure Highways division did “not oppose” it (noting no negative impact on highway safety or parking), and no neighbouring properties submitted any objection. This suggests that the development was not viewed as causing harm to the locality or countryside by those closest to it. By maintaining strict controls on how the unit operates (tourist use only, tied to the main house, limited occupancy lengths and all necessary amenity provisions on site), we ensure the use remains small-scale and benign. The proposal will not generate unacceptable noise, traffic, or visual intrusion – indeed, the nature of tourist stays means the unit is likely to be occupied only intermittently, and visitors are typically out enjoying the Island during the day.

Because the development can thus be accommodated without adverse effect on the countryside’s character or ecology, it accords with Environment Policy 1’s primary directive (protecting the countryside for its own sake) and does not require any “special override”. In summary, the absence of harm means the stringent “national need” test need not be engaged. Nonetheless, it is worth noting that at a strategic level, expanding the Island’s tourist accommodation is a national economic priority (as evidenced by the new strategies setting targets for visitor growth and accommodation supply – 500,000 visitors and 500 new tourist units by 2032). Approving this application would modestly contribute to those objectives. While not an “overriding national need” in isolation, the proposal is certainly in the national interest of supporting tourism – a material consideration the decision-maker can rightly weigh in the planning balance.

Reason 3: New Habitable Unit in the Countryside (Strategic Policies 2 & 8, Spatial Policy 5, General Policy 3)

Refusal Reason 3: “The proposal would undermine established policies of the Strategic Plan which indicate a presumption against the creation of new habitable units in the countryside… contrary to Strategic Policies 2 and 8, Spatial Policy 5 and General Policy 3 of the Strategic Plan.”

This reason underlines the core planning principle that, in general, new dwellings or independent residential units should be directed to existing settlements, not scattered in rural areas. Strategic Policy 2 of the Isle of Man Strategic Plan 2016 states that “new development will be located primarily within our existing towns and villages… Development will be permitted in the countryside only in the exceptional circumstances identified”

(such as those in General Policy 3). Likewise, Spatial Policy 5 of the Strategic Plan reinforces that “New development will be located within the defined settlements. Development will only be permitted in the countryside in accordance with General Policy 3.”. General Policy 3 (GP3) enumerates the exceptional cases

(e.g. agriculture, utilities, conversions, etc.) wherein countryside development may be allowed. Strategic Policy 8, specific to tourism, echoes that tourist proposals are acceptable in the countryside only where they reuse existing fabric of interest and do not harm environmental or highway interests. The previous decision considered our proposal tantamount to creating a new dwelling in the countryside, thereby conflicting with these policies.

Applicant’s Response: We fully appreciate the importance of the “no new dwellings in the countryside” presumption. However, we submit that this proposal does not, in any substance, create a new independent

dwelling, and it fits squarely within one of the exception categories provided for in the Strategic Plan – namely, the conversion and re-use of an existing building for tourism use, subject to criteria. This is a fundamentally different scenario from building a new house on a green field or splitting an agricultural holding into residential plots. Key points:

- • Not a Standalone New Build: The unit in question is within an existing building. No additional structures are being erected in the countryside. The Strategic Plan acknowledges conversion of redundant buildings as an exception to the general restriction (Housing Policy 4 allows “conversion of redundant rural buildings in accordance with Housing Policy 11” as an exceptional circumstance for housing). By analogy, converting an existing building for tourism is contemplated by Environment Policy 16 and supported by Business Policies 11 and 12 (which encourage “other forms of quality accommodation in rural areas” provided General Policy 3 is complied with). Thus, the proposal falls under a category the Strategic Plan envisions permitting in the countryside, rather than a wholly new development. We are effectively making use of an existing asset rather than introducing an entirely new residential unit into an undeveloped site.
- • Ancillary Nature & Single Planning Unit: This application confirms that the tourist accommodation will remain ancillary to Ballahutchin House and remain as part of the same planning unit. The garage and upper floor will share access, parking, and services with the main dwelling. It will not be sold or let as an independent residence; its occupancy will be controlled (via planning conditions) to shortterm holiday makers only. This approach mirrors the conditions imposed in the Lambfell Beg approval, where the unit “shall remain connected to the main house… and shall not be sold, rented nor used as a separate independent dwelling at any time”, and in the Kingsley Farm approval, where the site (dwelling and garage) “shall remain as a single planning unit and shall not be occupied separately”. By accepting a similar condition, the applicant ensures there is no creation of a new permanent household in the countryside. The unit will function as a temporary accommodation for visitors, analogous to a small guest suite associated with the main house (albeit with its own limited facilities).
- • Compliance with General Policy 3 exceptions: General Policy 3 (as referenced by Spatial Policy 5) allows certain developments in the countryside. Re-use of existing buildings, especially for business/tourism uses that support the rural economy, is one such scenario. The Strategic Plan’s Business chapter explicitly supports rural tourism enterprises, stating that “new forms of contemporary tourism development will be welcomed, particularly those that satisfy customer demand for high quality accommodation in rural areas provided that they comply with the policies in the plan”. It mentions encouragement for “quality self-catering units in barn conversions” and other innovative accommodations, so long as General Policy 3 and relevant Business Policies are met. Our proposal adheres to GP3 by virtue of being a conversion (not new build) and by not undermining any other policy (as we demonstrate throughout this statement). Therefore, granting permission would not “undermine” the Strategic Plan – on the contrary, it would be an application in accordance with the Plan’s balanced approach to countryside development (i.e. resisting unjustified new build dwellings, but allowing appropriate re-use projects). It is notable that both Lambfell Beg and Kingsley Farm approvals were determined to comply with Strategic Plan policies when conditions were applied; for instance, the Kingsley decision was found to “comply with Strategic Policy 8, General Policy 2 and Business Policy 13” and not to harm amenity, indicating alignment with the development plan even though the site was rural.

• Preventing Unrestricted Residential Use: A concern in the previous refusal (and officer’s report) was that a tourist unit could be used for longer-term occupancy or even effectively become a de facto dwelling, thus defeating planning controls. We address this by proposing a strict occupancy limitation: no single person or group will be allowed to occupy the unit for more than e.g. 4 weeks in any calendar year (aligned with the 28 or 31-day limits seen in similar approvals). A condition to this effect will ensure it remains short-let holiday accommodation only, preventing any continuous residential use. This, coupled with the tie to the main house, will remove the possibility of the unit turning into an “unjustified separate dwelling in the countryside”.

In summary, with these safeguards, the proposal respects the Strategic Plan’s countryside policies. It utilises an existing building without expanding the built footprint, keeps the unit firmly part of an established residential holding, and serves a purpose (tourism) that is supported by rural economic policies. There is a clear distinction between this controlled tourist unit and the kind of unrestricted new housing development that Strategic Policies 2 and Spatial Policy 5 are meant to prevent. We submit that the presumption against new countryside dwellings is not breached in this case; rather, this is a planned exception that the Strategic Plan allows and that recent Planning Committee decisions have endorsed in practice.

Reason 4: Business Policies 11, 12 and 14 Refusal Reason 4: By reason of the failures noted in Reasons 1–3 (non-compliance with Housing, Environment, Strategic and Spatial policies), “the proposal also fails to meet Business Policies 11, 12 and 14 of the Isle of Man Strategic Plan 2016.”

This essentially concluded that because the development was contrary to the aforementioned policies, it could not satisfy the specific tourism and business-related policies (Business 11, 12, 14) that govern tourist accommodation proposals. In the Strategic Plan’s Business & Tourism chapter, these policies set criteria for approving tourism developments, often cross-referencing the need to comply with General Policy 3 and not harm the countryside.

Applicant’s Response: We assert that by overcoming Reasons 1–3 as outlined above, the proposal now meets the requirements of the relevant Business policies. The Business policies in question (likely those addressing new tourist accommodation in rural areas) generally require that proposals: (i) comply with the general presumption against harmful countryside development (GP3), (ii) meet the conversion criteria (HP11/EP16) if applicable, and (iii) contribute positively to tourism objectives without adverse impacts. The previous refusal reason 4 explicitly tied the failure of Business Policies 11, 12, 14 to the failure of those other policies.

With this resubmission, we have demonstrated:

- • Compliance with GP3 (by falling under an exception and causing no countryside harm),
- • Compliance with HP11(c) and EP16(b) (by selecting a building of sufficient quality and interest to reuse, and ensuring its redundancy for former use),
- • Consistency with Strategic Policy 8 (tourist use of existing building of quality, enabling enjoyment of the area, without adverse environmental/highway effects), and
- • Consistency with Spatial Policy 5/Strategic Policy 2 (not introducing a new isolated dwelling, but an appropriate additional use of an existing building).

Therefore, the foundational causes of conflict with Business Policies 11, 12, 14 have been removed. Instead, the proposal positively engages Business Policy 5.5.5 – 5.5.7 content (to paraphrase): it represents a “new form of contemporary tourism development” that is “welcomed” in broad strategy; it provides “quality accommodation in [a] rural area” and thus broadens the Island’s tourist offer; and it complies with all relevant plan policies (GP3, etc.) as required. Business Policy 11 and 12 (though not quoted in full here) likely deal with specific types such as self-catering accommodation and their criteria – criteria we have now satisfied (e.g. via appropriate scale, design, and occupancy control). Business Policy 14 may pertain to related tourist enterprise considerations (possibly ensuring adequate infrastructure or preventing undue competition issues), none of which are problematic here given the minute scale and lack of objection from any quarter.

To reinforce this compliance, the proposal also adheres to best practice design and management for tourist accommodation. Although a minor development, it meets guidance such as the Residential Design Guide 2021 where applicable (for example, ensuring safe access and parking, appropriate lighting, waste management, etc.). In the Kingsley Farm approval, the Committee noted compliance with the Residential Design Guide and found no harm to neighbouring use, aligning with Strategic Policy 8 and Business Policy 13. Similarly, our proposal maintains high standards. Sufficient off-street parking space is available within the property (and can be formally allocated as required). Any external lighting will be minimal and can be conditioned to be wildlife-friendly (low-level, downlit) to protect dark skies and bats, consistent with measures in both Lambfell and Kingsley approvals. In short, the development can satisfy all relevant detailed considerations, reinforcing that it aligns with Business Policy aims to promote quality and avoid adverse effects.

In conclusion on this point, there is no longer any policy conflict: the proposal is in full accord with the Strategic Plan’s Business and Tourism policies that govern accommodation proposals. It demonstrates how a small-scale tourism project can be achieved within the letter and spirit of the plan.

## Compliance with the Isle of Man Strategic Plan 2016

Having addressed the specific reasons for refusal, it is useful to summarise how the resubmitted proposal stands with respect to the Isle of Man Strategic Plan 2016 – the principal policy document of the prevailing Development Plan. We highlight compliance with the key relevant policies:

- • Strategic Policy 2 (Development Location): The proposal represents an exceptional form of development in the countryside that the Plan permits. We are reusing an existing structure (conversion of a redundant building) – one of the “exceptional circumstances” envisaged for countryside development – and we have shown it meets the criteria for such reuse. Thus, Strategic Policy 2’s aim of directing development to appropriate locations is upheld.
- • Strategic Policy 8 (Tourism Development): This policy states that “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 man-made attractions.” Our proposal ticks all those boxes: it utilises an existing building of quality; it has no adverse effect on the environment (no new build, negligible additional traffic – as Highways raised no concern, and no loss of agricultural land); and it will enable visitors to enjoy the Island (providing a base close to walking trails, heritage sites, and accessible by

bus to Douglas, Peel and beyond). Strategic Policy 8 compliance is explicitly recognised in the comparable approvals (Kingsley Farm was found to comply with SP8), and we follow the same model.

- • Spatial Policy 5 (Defined Settlements and Countryside): As noted, this policy defers to General Policy 3 for any countryside development. We are in compliance with General Policy 3 because our development falls under conversion of an existing building and does not contravene any other general considerations (such as amenity, landscape or infrastructure capacity). We reinforce that no new “sprawl” or ribbon development is occurring – the site is just 70m from the main road and lies between the Glen Lough campsite and the village of Union Mills, so it is not isolated deep in the uplands but rather on the fringe of an existing settlement (Union Mills is identified as a “Service Village” in the Spatial Strategy). In effect, the location is highly sustainable for tourism: close to village amenities and public transport routes, meaning guests could use local shops/pub in Union Mills and potentially use buses, aligning with Strategic Policy 10’s encouragement to minimise car journeys. The small scale ensures the individual character of the area is preserved – Ballahutchin will remain a single dwelling with an ancillary tourist unit, not a new separate development.
- • General Policy 2 (Amenities of Neighbours and Landscape): While not explicitly cited in the refusal, GP2 (from the General Development Considerations) usually requires that developments do not unduly harm the amenity of neighbouring properties or the character of the area. We comply: no neighbours have objected, and the nearest unrelated dwelling is some distance away such that the use will be imperceptible to them. The character of the area (semi-rural with sporadic buildings) remains unchanged. By retaining the external appearance, the development is visually neutral. There will be no noise, lighting or activity beyond what a normal small household might generate. Thus, the amenity and character safeguards of GP2 are met.
- • Housing Policy 11 & Environment Policy 16 (Rural Building Conversion Criteria): As detailed under Reason 1, we satisfy the criteria: the building is structurally sound, redundant for its original use, of sufficient size and quality, and its conversion will preserve the fabric. It is also serviced (power, water, drainage) already, so criterion (f) of HP11 (services without unreasonable public expenditure) is fulfilled. Notably, the Officer’s Report for the previous application acknowledged that Strategic Plan policy does allow conversion of buildings in the countryside for tourist use, provided they meet HP11 and EP16 and do not undermine other policies. We have ensured our proposal meets those provisos, thereby placing it firmly within the policy framework rather than outside it.
- • Environment Policy 1 (Countryside Protection): We reiterate compliance here: no adverse effect, so the development is consistent with the protection of the countryside’s appearance and ecology. By using an existing building, we avoid encroachment on open land.
- • Environment Policies 2 and 16: Environment Policy 2 concerns protection of Areas of High Landscape Value etc., which is not directly relevant since the site is not in a designated landscape. Nonetheless, the spirit – avoiding harm to landscape character – is respected (no visual change). We have addressed Environment Policy 16 in detail; all its sub-clauses (a through to f) are satisfied in this resubmission: redundancy (a) and structural integrity – yes; preservation of fabric of interest (b) – yes, we retain a good quality building; no extension or adverse appearance change (c) – yes; no traffic issues (d) – confirmed by Highways; no dispersal that prejudices town/village vitality (e) – one unit will

not draw any activity away from towns, and visitors will still likely spend time (and money) in towns and villages; and minimal redevelopment – actually none required – so clause (f) about benefits outweighing impacts is met since benefits (tourism spending, building upkeep) outweigh the negligible impact of reuse.

• Business Policies 11, 12, 13, 14: Our analysis under Reason 4 demonstrates compliance. In particular, Business Policy 13 (cited in the Kingsley Farm decision) appears to relate to ensuring no harm to others and qualitative standards – we comply as there is no harm, and quality will be assured. Business Policy 11 and 12 likely concern self-catering and other non-serviced accommodation – our proposal aligns by providing a “distinctive, contemporary… non-serviced accommodation” unit, which is exactly what the Visitor Economy Strategy now calls for.

In summary, the proposal is now in line with the Strategic Plan 2016. We have designed the resubmission to satisfy each relevant policy criterion. Any residual tension (for instance, the building not being “historic”) is outweighed by the considerable conformity to the rest of the plan and the wider strategic benefits. The Strategic Plan must be read as a whole, and on balance this proposal supports many of its core aims: re-use of existing resources, supporting diversified economic opportunities, and sustainable development without environmental harm.

## Compliance with the Area Plan for the East (2020)

Under the Area Plan for the East 2020 (APE), the site at Ballahutchin House lies outside any defined settlement boundary and is not allocated for development. In the APE, Union Mills is identified as a village with a development boundary; Ballahutchin House is just outside that boundary, thereby falling under the designation of “countryside” in planning terms. The APE defers to the Strategic Plan for general policy on countryside development. There are no specific site policies or zoning constraints (such as conservation area or scenic area status) affecting the property in the APE. Thus, the relevant considerations remain those of the Strategic Plan, which we have addressed above.

It is worth noting that the APE contains “Tourism Proposals” encouraging new tourist accommodation within settlements (Tourism Proposal 2 supports new or improved tourist accommodation in eastern settlements), and it seeks to retain existing tourist uses unless unviable. While our proposal is outside a settlement, it does not conflict with these aims – rather, it complements them by adding capacity in close proximity to a settlement. Union Mills, as the nearest village, stands to benefit from visitors staying at Ballahutchin (through use of local services), consistent with the APE’s goal to support local economies.

The Area Plan for the East’s countryside policies essentially mirror the Strategic Plan’s: development outside defined settlement boundaries is tightly controlled. We have demonstrated the proposal fits the exception of conversion of an existing building for economic use, permissible under Strategic Plan policies that the APE continues to apply. The APE did not introduce any new restriction that would prohibit this development; nor did it identify this particular area for any special protection beyond normal countryside. Therefore, by complying with the Strategic Plan, the proposal complies with the Area Plan for the East.

In practical terms, the APE’s adoption since the original garage was built reinforces the fact that Ballahutchin House remains in the countryside zone, and we have treated it as such in our policy assessment. No change in zoning occurred that would either specially permit or specially forbid the proposed use on this site. We

simply ensure conformity with the APE by adhering to all relevant Development Control policies (design, access, drainage, etc.) and respecting the plan’s overall strategy.

In conclusion, the proposal is consistent with the Area Plan for the East 2020: it does not seek to undermine the development hierarchy (since it’s an allowable exception type), and it yields economic benefits in line with the Plan’s support for the visitor economy. There is no conflict with any specific provision of the APE.

## Material Changes in Circumstances – New Strategies (2022)

Since the refusal in October 2022, two significant strategy documents have been published and adopted by the Isle of Man Government, which constitute a material change in circumstances and provide strong support for the proposal. These are:

- • “Our Island, Our Future” Visitor Economy Strategy 2022–2032 (approved by Tynwald in late 2022), and
- • Our Island, Our Future – Isle of Man Economic Strategy (2022–2032) (published November 2022).

These strategies clearly amplify the importance of growing the Island’s visitor accommodation sector and form part of updated Government policy that did not exist at the time of the previous decision.

## Visitor Economy Strategy 2022–2032

The Visitor Economy Strategy sets ambitious targets and objectives for tourism over the next decade. Key points from this strategy include:

- • A headline target to increase annual visitor numbers to 500,000 by 2032 (approximately doubling the pre-strategy levels) and to raise the annual economic contribution of tourism to £520 million. Achieving this will require substantial expansion in accommodation capacity across the Island, as recognised in the strategy’s action plans.
- • An objective to deliver “500 new units of distinctive, contemporary eco-friendly non-serviced accommodation” by 2032, alongside new hotel bedspaces. This is a quantitative goal directly relevant to our proposal – each approved unit counts toward that 500. Approving the Ballahutchin House unit would be a step toward the target, whereas refusing it would place a greater burden on other developments to meet the demand.
- • The strategy identifies that the Island’s current accommodation offer lacks variety and needs modernisation and innovation. It specifically notes: “We are lagging behind our competitor destinations in terms of the quality and choice of visitor accommodation that we offer. We need to secure investment in distinctive, contemporary and eco-friendly visitor accommodation that will attract new visitor markets, help to boost off-peak demand, and enable the Island to get ahead of the competition.”. The proposed development answers this call by providing a modern, private accommodation option that will appeal to visitors (particularly those seeking self-catering or “home away from home” lodging). It also helps with off-peak tourism – such units can be marketed yearround, including to niche off-season visitors (e.g. wildlife enthusiasts, walkers) looking for rural stays.
- • The strategy’s Action Programme 3: Visitor Accommodation Transformation encourages widening the non-serviced accommodation supply with innovative offerings, including rural retreats. Our proposal aligns well as a small rural retreat. Even though it is a single unit, collectively many such units will

form the “widened supply” the strategy envisions. The previous Non-Serviced Accommodation Policy

(2019) – which was referenced in the refusal – has effectively been subsumed by this 2022 strategy, which adopts a more urgent and proactive stance. The earlier focus on certain types is now broadened to any accommodation that adds quality, uniqueness, or capacity in under-served segments. In this context, a one-unit development is not seen as too minor; rather, it is one piece of a larger puzzle, contributing to diversity of accommodations (in fact, the strategy emphasises encouraging even unconventional accommodations like treehouses, cabins, etc., showing that scale is not the sole determinant of value).

In summary, the Visitor Economy Strategy represents a material consideration of significant weight that strongly supports granting permission. It indicates a policy shift: where previously there may have been hesitancy to approve small-scale tourist units in the countryside, the new direction is to welcome and facilitate appropriate accommodation projects to meet growth goals.

## Isle of Man Economic Strategy 2022

The Island’s Economic Strategy, also branded “Our Island, Our Future,” provides the macro framework for economic growth and diversification. It identifies the Visitor Economy as one of the key sectors to develop (alongside Digital, Finance, etc.). Specifically, it calls for delivering on the Visitor Economy Strategy 2022 to “modernise and expand” the Island’s tourism proposition. This is a clear mandate that the planning system should enable suitable tourism developments as part of the broader economic vision.

The Economic Strategy notes that increasing visitor spending and numbers will contribute to community prosperity and that tourism growth will also enhance the Island’s attractiveness as a place to live (by supporting services, transport links, etc.). The proposal before you, while modest, feeds directly into these economic objectives by:

- • Expanding the tourism product: It adds a new accommodation option that can be marketed in tourism campaigns (e.g. through Visit Isle of Man’s website). Each new accommodation, even if small, increases the Island’s capacity to host visitors and signals that the Island is open for tourism business.
- • Supporting local economy: Visitors staying at Ballahutchin will spend money on meals, entertainment, shopping and activities in the area, thus injecting money into local businesses. This aligns with the Strategy’s theme of spreading economic benefit. Rural tourism brings income to areas outside Douglas, supporting balanced regional development.
- • No public cost, but public benefit: This private initiative does not require public infrastructure investment (the site is already serviced). Yet it yields public benefit in terms of tax revenue from tourism and sustaining employment (albeit indirectly through visitor spend). It’s exactly the kind of low-impact, privately-led growth the strategies encourage.

By adopting these strategies, Tynwald has effectively signalled that previous approaches should be revisited in light of current priorities. The refusal in 2022, based on pre-2022 criteria, did not have the advantage of considering these strategies (the Visitor Economy Strategy was only just being finalised). Now, in 2025, we have a much clearer steer: supporting the visitor economy is a governmental priority of the highest order. As a result, the planning balance should tip in favour of well-managed tourist accommodation proposals even where they might have been viewed less favourably before. Indeed, the Lambfell Beg application – initially

recommended for refusal in 2024 – was approved by the Planning Committee, explicitly referencing that its small scale and connection to the main house meant it “was considered to have limited harm and to meet with the DfE Visitor Economy Strategy”, with conditions ensuring tourism-only use. This demonstrates that decision-makers are now giving substantial weight to the new Strategy. The same approach should be applied here.

In conclusion, the material change in circumstances brought about by these 2022 strategies provides compelling justification to approve the resubmitted application. Any marginal policy concerns can be mitigated by conditions, while the positive economic and strategic merits of the proposal carry increased weight. To refuse the application again, despite these new policies, would risk inconsistency with the Island’s declared economic direction.

## Comparable Planning Approvals (Lambfell Beg and Kingsley Farm)

It is helpful to consider two recent, directly comparable planning approvals which indicate a supportive stance toward developments like this proposal. While every application must be determined on its own merits, these cases provide a useful benchmark and demonstrate precedent for overcoming similar issues:

- • Lambfell Beg, St Johns (24/00211/C) – Conversion of an existing garage/office to tourist accommodation (Class 3.6). This application in 2024 was initially recommended for refusal by officers on grounds very similar to those in our 2022 case (the building was not historic, concerns about new unit in countryside, etc.). However, the Planning Committee approved the development in November 2024. In the Decision Notice, the Committee acknowledged that “despite those policies against development in the countryside and… criteria for conversion of rural buildings… given the small and ancillary scale of the proposed tourist unit (one bedroom and connected to the main dwelling) it was considered to have limited harm and to meet with the DfE Visitor Economy Strategy”, with conditions to ensure tourism-only use and tie to the main house. This is almost directly applicable to our proposal: we likewise propose a one-bedroom unit, ancillary to the main house. By imposing the same kind of conditions (which we welcome and have pre-emptively outlined), any policy tensions are resolved. The Lambfell Beg approval sets a clear example that policy flexibility can be applied for small-scale tourist units, especially in light of the Visitor Economy Strategy. We intend to replicate Lambfell’s model of control: the unit will remain part of the Ballahutchin House property, used only for short-term holiday lets, not separately sold or let long-term, and with prior provision of parking and sensitive lighting as required. If Lambfell was acceptable, so too is Ballahutchin – arguably even more so, as Ballahutchin’s building is newer (fully up to modern standards) and its location is closer to central infrastructure.
- • Kingsley Farm, Ballasalla (24/91102/B) – Garage conversion to provide tourist accommodation, approved January 2025 by the Planning Committee. Conditions on this approval similarly required the site to remain a single planning unit with the main dwelling (no separate occupation) and limited any one occupier’s stay to 28 days/year, explicitly “to prevent the creation of an unjustified separate dwelling in the countryside.” Additional conditions controlled parking provision and removed certain permitted development rights to avoid future uncontrolled expansion. The decision rationale noted that the application caused no harm to neighbours and complied with Strategic Policy 8, etc., and was therefore recommended for approval. The Kingsley Farm case underscores that, when well-managed, such conversions do not harm residential amenity or the character of the area. In our case, we have

even fewer immediate neighbours and ample existing parking, so any potential impacts are minimal or nil – comparable to Kingsley which was found acceptable on those terms.

The above approvals show a pattern: the Planning Committee is willing to approve tourist accommodation units ancillary to dwellings in the countryside, provided conditions ensure they remain ancillary and used for tourism only. This is exactly what we propose here. We respectfully assert that it would be inconsistent for our proposal to be refused now, given that it mirrors the circumstances of Lambfell Beg and Kingsley Farm which the Department/Committee have deemed acceptable and in line with policy (as recently as this year). Consistency in decision-making is a principle of good administration. While we acknowledge each case must be judged on its own facts, we believe the facts here align closely with those precedent cases, with no unique detriment posed by Ballahutchin that would warrant a different outcome. On the contrary, Ballahutchin House’s location (near a village and a tourist campsite) makes it arguably even more suitable, as it reinforces an existing cluster of tourist activity (Glen Lough campsite) – aligning with the idea of “clusters or separate small-scale units which complement existing tourist activities” noted in the Non-Serviced Accommodation study.

In conclusion, the Lambfell Beg and Kingsley Farm approvals serve as material considerations indicating that the Department’s interpretation of Strategic Plan policies, considering current strategies, is to facilitate (with conditions) these kinds of developments. We have modelled our resubmission to reflect the conditions and considerations in those approvals, thereby ensuring a consistent approach. The presence of these comparable cases should give the decision-maker confidence that approving this application is not an outlier move, but rather entirely in line with the Department’s recent decisions and the Island’s planning direction.

(For completeness, we note that both approvals were in the Glenfaba and Malew areas, showing that multiple regions are benefiting from such tourist unit permissions. Approving this application would extend that benefit to the Marown area, spreading the tourism opportunity Island-wide.)

## Conclusion

This resubmitted proposal for the use of the existing garage loft at Ballahutchin House as tourist accommodation is persuasively justified on planning policy grounds. We have directly addressed the previous reasons for refusal and made appropriate amendments and commitments to ensure compliance. In particular:

- • The building, while not historic, is of high quality and visual merit, and its conversion (with no external alteration) will preserve the rural character. It meets the conversion criteria of the Strategic Plan (HP11 and EP16) when considered in light of its architectural quality and the lack of any physical expansion.
- • The proposal, though small in scale, aligns with and helps deliver the objectives of the Visitor Economy Strategy 2022–2032, a newly adopted policy framework that seeks to expand and modernise the Island’s tourist accommodation. This represents a significant positive material consideration that was not previously weighed.
- • With conditions tying the unit to the main dwelling and restricting occupancy to bona fide short-term holiday use, there is no risk of an unwarranted new dwelling being established. The development remains an ancillary one-bedroom suite within the curtilage of an existing house – a form of

development the Strategic Plan allows in the countryside under exception policies. Thus, the integrity of the countryside is maintained, satisfying Strategic Policies 2 and 5 and Environment Policy 1.

- • There will be no adverse effects on neighbours, infrastructure, or the environment. The site is already serviced and accessed. No additional buildings or major works are proposed. The local Highway Authority did not object, and there were no neighbour objections previously, indicating general acceptance of the use. Future operations will be managed to remain neighbourly and low-key.
- • The economic and tourism benefits, albeit modest, are real and countable. Every new tourist accommodation adds capacity, choice, and resilience to the Island’s visitor economy – in this case with virtually zero negatives. Approving this application would send a positive signal to other property owners that they can contribute to the Island’s tourism targets in a responsible way, thereby encouraging the distributed growth that the Government seeks.

In light of the above, we respectfully conclude that the planning balance now weighs firmly in favour of approval. Any lingering policy reservations are overcome by the proposal’s compliance with the development plan when read as a whole, coupled with the clear support from updated national strategies and recent comparable decisions. Conditions can be imposed (and are indeed anticipated by the applicant) to secure the ancillary status and tourist-only use, as well as any other matters the Department sees fit (such as parking layout or lighting details), in order to cement the policy compliance and prevent misuse.

We therefore request that the Department grant planning permission for the additional use of the first-floor of the detached garage at Ballahutchin House as tourist accommodation (Class 3.6). This will allow the Isle of Man to gain a small but valuable new lodging unit in time for upcoming visitor seasons, contributing to the Island’s strategic tourism goals while safeguarding the character of the countryside through appropriate controls.

The proposal represents a sustainable form of development that accords with the Isle of Man Strategic Plan 2016 and the Area Plan for the East 2020, and it is bolstered by material considerations of considerable weight. We trust that the information and assurances provided in this statement adequately address the previous reasons for refusal and demonstrate the proposal’s merits.

## Ste Stanley, Uplift Planning Chartered Member of the Royal Town Planning Institute

---

*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/34076-union-mills-ballahutchin-house-garage/documents/1085757*