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Current Applicant's Response to issues raised by Inspector C A Jenkins when he rejected the previous application on 20 November 1996
Para 2: Only a portion of the land rises very sharply from the roadside on the eastern boundary, amounting to approximately 30% of that sloped area. The remainder could be described as rising sharply but not to an extent where sheep are prevented from easily grazing the slope. Please note the primary agricultural output of the current applicant is sheep, rather than cattle as per the previous applicant. Even the area best described as rising very sharply can be grazed safely by sheep down to the Sulby Glen Road. This has been observed frequently by the current occupier. The eastern slope area of Mount Karrin Farm has historically been serviced by a small area on the eastern side of the Sulby Glen Road. This is adjacent to the stream opposite and forms part of the farm's documented area. There are old but well established holding yards for working sheep. These yards are currently not used and overgrown but are part of Mount Karrin Farm. The existence of these long standing working yards for sheep on the Sulby Glen Road is firm historic evidence of past normal usage of the eastern slope of Mount Karrin Farm and confirms Mount Karrin Farm was run as a whole over 400 acres as a sheep enterprise. This is contrary to Inspector Jenkins' general assertion but in fairness to him he was making an assessment on the basis of the unique cattle enterprise existing at that particular time in 1996. Cattle rearing does not seem to have been the usual or historic agenda at Mount Karrin Farm as evidenced by the fencing structures which were for sheep. There are well established stock grids on the Sulby Glen Road at either end of Mount Karrin Farm. These are yet further evidence of historic use of the steep eastern sloped pastured area immediately adjacent and rising directly from the Sulby Glen Road. A substantial and historic stone fence has been erected at both ends of the steep sloping eastern area to a degree where if the area was as unusable and unviable as Mr Jenkins generally implies, the substantial long standing and extensive fencing would not have been erected.
Para 3: The "narrow strip of land" described by Mr Jenkins can nevertheless easily accommodate a modest farm worker dwelling with a moderate surrounding garden area. It is in any event, larger than most urban building plots on the Isle of Man.
Para 4: Mr Jenkins describes... "a rough, narrow and very steep track winding up the side of the mountain. This is apparently the only access to the higher ground and to the pasture for the animals from the proposed farm house." In fact, the track is currently well formed, stable and as wide as some areas of the publicly maintained Sulby Glen Road. The access track rises easily to the higher pasture land and has multiple switch backs and turn areas that enable sheep and vehicles to move up and down as required for routine stock and general farm
management. The road also services the moderately sloping pasture area immediately above the proposed building site.
Para 5: Currently the proposed building site is not visible from the surrounding area to an extent where it would perhaps be one of the most sheltered dwelling sites at Sulby Glen. With the passage of time the switch back road rising to the higher area has become overgrown with natural habitat and therefore blends into the area as well or better as many of the surrounding roads.
Para 6: Mount Karrin Farm is currently being run as a viable sheep grazing, breeding and fat lamb rearing enterprise supporting at least 300 breeding ewes and followers. This requires approximately 1500 hours of supervision as per Manx Agricultural Department recommendation at 5 hours per sheep per year. This approximates an average working year for one full time employee and is usual for this size enterprise. The position of the worker's accommodation on the lower area is especially important for supervision of sheep when they graze over the eastern slope area, as this area is unfenced at the road and historically has always for many years encompassed the Sulby Glen Road where on occasion stock may require additional care and supervision. In addition the area surrounding the proposed farm workers dwelling is well suited for lambing supervision and general husbandry with easy access to the Sulby Glen Road for general farming supplies. There is a large shed immediately adjacent to the proposed site. It is unlikely Government approval will be given to build similar alternate shedding on the higher areas of Mount Karrin Farm so the proposed site at the existing intensive shedding facility is the only likely area available. It already has town water connected. Electricity supply is immediately adjacent to the existing shed and proposed building site. There are well constructed long standing multiple small stone fenced holding paddocks immediately above the proposed building site. This indicates consistent past historic use of the area for intensive stock management. The current overgrown nature of the area is a result of restricted use in recent years. This is contrary to the clear long standing historic agenda and functional requirement of the site, where the enterprise would have been much more labour intensive.
Para 10 & 11: Planning Circular 3/88 accepts that exceptions to the policy of strict control in the countryside are possible for viable agricultural holdings. Planning circular 3/88 sets out tests to be considered before approval can be granted. This application meets all the tests as follows
a) Agricultural need is established. b) There is no existing dwelling on Mount Karrin Farm. c) The Applicant will occupy the building and farm the land. d) The site is well located close to farm buildings, well back from the Sulby Glen Road and with proper all weather access. e) Design matters are to be settled later but in this instance the applicant will accept any reasonable Departmental recommendation as to size, site and design for the proposed worker's accommodation.
f) An agricultural occupancy condition is acceptable to the Applicant.
Para 13: The proposed site is not generally visible from the surrounding area and the Applicant will undertake, if successful, to maintain the barrier of existing natural habitat immediately adjacent to the Sulby Glen Road. This will preserve the current general high scenic value of the area. The proposed farm workers building site is near the existing shedding on Mount Karrin Farm which currently cannot be seen from the Sulby Glen Road or surrounds despite it being a much larger structure than the dwelling now proposed in this application.
Para 14: The current Applicant does not have any other farming land. It is usual for viable farming enterprises to be supervised from at least one area where there is suitable immediate accommodation to enable close on site supervision of the enterprise as and when required. Albeit that this is not necessarily required at all times but nevertheless often enough to justify the proposed on site dwelling for efficient operation and where Agricultural Department figures as to labour requirement support it.
Para 15: Mount Karrin Farm has consistently been run as an enterprise of at least 300 breeding ewes and followers with fattening of male progeny to sale. However Government regulation has inhibited full usage of the historic whole farm area in that the sloping area running from and including the Sulby Glen Road now requires even closer regular supervision given the modern traffic flow. These changed conditions were not caused by the Applicant and it would be unfair to inhibit the Applicant's pragmatic response to the altered circumstances outside their control. A member of the public recently required the current occupier to check a sheep late at night, apparently slightly limping beside the Sulby Glen Road. The sheep was healthy and simply camping for the night within the confines of Mount Karrin Farm beside the Sulby Glen Road, as they do on occasions. A successful building application would restore suitable on site accommodation for a resumption of the required closer supervision which would have been the historic agenda. It would enhance and continue the general viability of the farming enterprise on Mount Karrin Farm.
Para 16: The Applicant has enclosed operational financial figures to establish the long term viability of Mount Karrin Farm. The figures are consistent with those of a usually viable sheep farming enterprise on the Isle of Man. This is supported by the proposed Government farming support payment which approximates 4% of the current land value of Mount Karrin Farm. The sloping area adjacent to the Sulby Glen Road, uniquely, greatly increases the general viability of Mount Karrin Farm where that sloped area is protected from heavy snow inundation. This has enabled extensive sheltered, prolonged and life saving sheep grazing during severe winter conditions. This was recently evident during the immediate past winter months. Many sheep enterprises on the Isle of Man were required to invoke emergency sheep husbandry procedures to prevent heavy losses when deep snow inundation severely inhibited viable grazing.
Para 17: The Applicant does not have any other land on which stock could be more closely supervised as and when required and currently the farming enterprise lacks the necessary facilitation and convenience of accommodation for a farm worker.
Para 18: The proposed building site has historically been used as an intensive stock holding area as evidenced by the small long standing stone walled holding paddocks immediately above the proposed building site. This area has obviously been used for many years predating the current shed, as a close and convenient area to confine sheep for intensive husbandry. In addition there is a reasonable area of some acres immediately below the existing shed. This could also easily be used for closer supervision of stock but in any event to an extent and separation usual on the Isle of Man for a similar size enterprise to that which is currently being conducted at Mount Karrin Farm.
Para 19: The suggestion that an Applicant should purchase an existing dwelling away from the farm in lieu of constructing a dwelling on farm is unreasonable, self-serving and fails to be objective. It would reduce the viability of the current enterprise in additional unnecessary cost and diminished general workability. The public road to Sulby Glen is not suitable for driving large numbers of sheep to a separate area there for husbandry and general close management. This was suggested as an alternative by Mr Jenkins. It is unworkable and an unreasonable suggestion even if in the unlikely event suitable land was available in the immediate area at a viable price befitting the current size of the enterprise. On one hand Mr Jenkins suggests the enterprise is not viable while on the other hand he proposes purchase of additional remote land for a house and close stock husbandry, presumably at the much higher urban residential price. This is both contradictory and a most unfair imposition on any farming enterprise where input costs are increasingly disproportionate to revenue and outside the farmer's control.
Para 20: These comments are unreasonable and appear to reflect a personal view contrary to that determined by Government regulation and set down in Planning Circular 3/88.
Para 21: These comments again appear to reflect a personal view and are contrary to Planning Circular 3/88.
Para 22: The area of Mount Karrin Farm as 400 acres, comfortably carries at least 300 breeding ewes and followers and in addition enables final preparation of male progeny for sale as fat lambs. The area as such enables full support of the stock all year round in most years. This is contrary to the situation on more ordered land which may be perceived as more viable. Many would agree that less concentrated grazing rates greatly diminish worm and general disease build up. This contributes to improved long term health of stock which in turn contributes to the general long term viability of an enterprise. Stated stocking rates on lower level more ordered land frequently fail to account as to viability of the frequent recurrent requirement for extensive supplementary feeding at additional cost when the land is unusable by overgrazing or waterlogged. The natural habitat and fertile natural pasture on Mount Karrin Farm is better preserved and persists due to the lower overall stocking rate per acre. The viability of hill grazing is in part relative to the initial cost of the land for a given stocking rate. General, simplistic and non specific comments as to the non viability of hill grazing may well fail to take this into account, are unhelpful and appear to be self serving in this instant.
Para 23: The Applicant will accept Departmental advice as to the location, size and style of the proposed dwelling at Mount Karrin Farm.
Para 24: The past comments again appear in part to express a personal view and are contrary to Planning Circular 3/88. The view may reflect a view in relation to the cattle enterprise that existed at the time of that assessment which is not relevant to the current application.
Para 25: The proposed area has matured to an extent where there is more than adequate screening by natural habitat to maintain the external unique appearance of the area. In particular the proposed dwelling would not be visible by passing traffic, contrary to most dwellings in the immediate area.
Para 26: The past comment as to the proposed area being of "limited capacity" appears to again reflect a personal view. It fails to take into account the proposed site as befitting the usual area required for a modest dwelling at Sulby Glen. Planning Circular 3/88 does not set out any special requirement or test as to limited capacity. The Inspector's report fails to take into account the existing long standing extensive permanent holding paddock structures immediately adjacent to the proposed building site. This area exceeds that of usual immediately surrounding infrastructure on most farms.
Para 27: The Inspector's comments in this paragraph are not relevant to the current application. There is abundant evidence on site to suggest the present application maintains and enhances the long-standing historical agenda of Mount Karrin Farm. It has been operated as a 400 acre unitary area for many years. The current improved track up to the higher area is not rough and not steep. It has been well constructed and is fully operational.
Para 28: The Inspector's comments again appear to express a personal view. Planning Circular 3/88 does not set down any requirement or test for an Applicant to acquire a secondary remote site or dwelling.
Para 29: The Inspector's acceptance of necessary close monitoring and support for an intensive rearing unit applies equally in this new application where the specific requirement would be for a supervised lambing area or pre sale fat lamb preparation with grain feeding. There is no intention for any alternate use of the proposed building site other than to enhance the farming operation.
Para 30: The past comment in this paragraph again appears unrelated to the requirements set down in Planning Circular 3/88 and appears to exceed the intent of that Planning Circular.
Para 31: There is no intention for the current Applicant to increase the capacity of the area in question. The area has been used as a close supervision site for many years as evidenced by the historical structures in situ above the proposed building site.
Para 32: Some of the perceived difficulties mentioned by the Inspector's 1996 report relate to a cattle enterprise and these reasons are not relevant to the current building application. The remainder of the comments appear to be generally self serving, are not objective and appear crafted to serve a pre conceived desired result. Planning Circular 3/88 does not set down any requirement or test relative to the reasons as applied by Inspector Jenkins. The Inspector's report appears to ignore or repudiate current standard precedents for the proper care of farm workers. There is a requirement for at least minimal toilet and eating facilities adjacent to the farming facility at Mount Karrin Farm. In addition it is reasonable that proper sleeping accommodation is provided for staff and family near at hand when staff are required to work after hours.
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