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1.1 The application site forms the curtilage of the land adjacent to Waterfall, Shore Road, Glen Maye which is a parcel of undeveloped land which is current used as a beer garden and the car park both of which are used in connection with the Waterfall Hotel. The site is located south of the Waterfall Hotel and Shore Road and west of the A27 Road.
2.1 The application seeks approval for erection of a residential development comprising three apartments and one house. The proposed building and communal gardens would be sited within the existing lawned beer garden, although the submission does propose to extend the north-eastern boundary of the existing lawned area by approximately 0.7 metres into the existing car park area.
2.2 The proposal would be set over two and three storeys located approximately 23 metres south of the Waterfall Hotel. The proposal would have a maximum width of 8 metres, a depth of 16.4 metres and a maximum height of 10.2 metres. A total of eight parking spaces are proposed along the north-eastern boundary of the proposed new residential curtilage of the site.
3.1 The application site is within an area recognised as being an area of "Residential/Woodland" under the Isle of Man Development Plan Order 1982. The site is not within a Conservation Area; nor within an area zoned as High Landscape or Coastal Value and Scenic Significance.
3.2 Due to the site location, zoning and the type of proposal, the following policies are relevant for consideration:-
The Spatial Distribution Policies within the Strategic Plan set out the hierarchy of settlements, indicating that Douglas will remain the main employment and service centre for the island, with other towns as supporting service centres. Some large villages are identified as service villages where appropriate increase in employment and housing should be provided to meet
local needs. Glen Maye, is classified as not within any of those service villages and consequently Spatial Policy 4 set out that these villages should maintain the existing settlement character and be of an appropriate scale to meet local needs for housing and limited employment opportunities. Area plans will define the development boundaries.
"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:
"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 housing will be permitted in the countryside only in the following exceptional circumstances:
"Environment Policy 3: Development will not be permitted where it would result in the unacceptable loss of or damage to woodland areas, especially ancient, natural and semi-natural woodlands, which have public amenity or conservation value."
"Environment Policy 9: A precautionary approach(1) will be adopted for development relating to land affected, or likely to be affected, by erosion or land instability. In the case of receding cliffs, development will not be permitted in areas where erosion is likely to occur during the lifetime of the building."
"Environment Policy 28: Development which would be at risk from ground instability or which would increase the risk from ground instability elsewhere will not be permitted unless appropriate precautions have been taken."
"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."
"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."
4.1 The following planning applications are considered relevant in the assessment and determination of this application:
4.2 Approval in principle for the erection of a dwelling. A two year extension was approved to the AIP by delegated minute 2.6 6/10/06 - 04/01421/A - APPROVED
4.3 Provision of cafe, flat, holiday accommodation and garage - 93/00097/B – APPROVED
4.4 Approval in principle for construction of cafe with flat and holiday accommodation - 93/00097/B – APPROVED
5.1 Patrick Commissioners have objected to the proposal which can be summarised as; out of keeping with the area and represents an overdevelopment of the site; number of dwellings accepted under the Strategic Plan for the west of the island has already been exceeded, therefore no need for any new housing pending consideration of the Western Area Plan; reserving 8 spaces in the car park for occupants of the dwelling would significantly reduce the capacity if the car park for both patrons of the Waterfall Hotel and visitors to Glen Maye for whom the owners are, it is understood, obliged to allow parking spaces in the car park; car park is often well filled during fine days and weekends; application 09/02097/B for a glazed extension to the Waterfall Hotel the applicant indicated at the appeal hearing that the beer garden would be used to accommodate smokers, there this new application would appear to be in conflict with the statement made at that time.
5.2 Highways Division have recommended an approval of the application.
5.3 The Department of Environment, Food and Agricultural (Forestry, Amenity and Lands Directorate) have objected to the proposal which can be summarised as; there are large trees very close to the southern boundary of the development site which are likely to be affected. The trees are situated within Glen Maye National Glen just beyond the southern boundary of the proposed development; Overhang/shading from these trees is likely to be an issue for the development as proposed; There is a rookery in the trees identified above, these birds can be noisy and create some mess, and might therefore be perceived as a nuisance to new residents; We would not sanction the removal of trees for these reasons; We question whether it is wise to build in a position that is likely to generate such an issue; The Glen Maye Area of Special Scientific Interest is in the vicinity of the development, but not abutting it; There should be no disturbance to the ASSI permitted as part of any development; The Department has the right by Deed of May 1960 to allow its visitors to the National Glen shared use of the full extent of the current car park area. No agreement has been made to vary this arrangement. It is therefore not possible to provide dedicated parking for the proposed development within the existing car park. In addition, part of the proposed garden area for the development appears to take part of the current car park. The current car park offers in the region of 50 available parking spaces and post-development would only offer between 30 and 35. The car park is regularly very busy and overflows (which we understand causes problems with local residents) and the loss of these parking spaces will inevitably have an impact upon visitors to the National Glen. This will clearly have an impact upon the tourism
and amenity values of the area; and in this regard, the Department feels that it must object to the proposed development as the plans currently stand.
5.4 The Department of Environment, Food and Agricultural (Forestry Division) have objected to the application which can be summarised as; concern with regards to this proposed development is that the trees located on the perimeter of the glen may be affected in the future; The close proximity of the trees in relation to the dwelling will obviously have an affect due to safety and light issues; and this may result in any occupier applying to this department for a felling licence for remedial work to be undertaken and or felling of the trees.
5.5 The Water and Sewerage Authority have no objection to the proposal subject to conditions.
5.6 The Manx Electricity Authority and Environmental Protection Unit & Public Health, make no comment on the merits of the application but ask an informative note be attached to any approval.
5.7 The owners/occupiers of 2 The Falls, Shore Road, Glen Maye have objected to the proposal which can be summarised as; proposed development would be obtrusive and spoil the enjoyment of the Glen; a simple cottage would be acceptable, however 3 apartments is excessive; and anyone in the Glen would be overlooked by the development spoiling their enjoyment.
5.8 The owner/occupier of Glenville, Glen Maye Hill, Glen Maye has objected to the proposal which can be summarised as; proposed three storey building is completely out of keeping with all properties within Glen Maye none of which are over two storeys in height; 30% of the existing car parking serving the Waterfall Hotel and the Nation Glen will be removed, this will have an impact upon the public highway due to an increased number of residents/visitors having to park on the A27 impact upon highway safety; detrimental impact on the sensitive balance of flora and fauna in the Nation Glen and impact on the enjoyment of this unique facility for members of the public; and there is no shortage of different housing types in Glen Maye and question the need of the development.
5.9 The owner/occupier of Hillside, Glen Maye has objected to the proposal which can be summarised as; proposed three storey building would be the only building of this height in the village, which is mainly Manx cottages; loss of parking resulting in car parking on the hill (A27); and not aware of any local residents support scheme contrary to applicants statement.
5.10 The owners/occupiers of 1 Glen Close, Glen Maye have objected to the proposal which can be summarised as; not aware of any local residents support scheme contrary to applicant's statement; no shortage of different housing types in Glen Maye and question the need of the development; loss of car park, this would put additional pressure on Glen Close which is a quiet residential area which can already be used as a overspill for visitors of the area; the development is not in keeping with the houses in this area which comprises mainly bungalows and traditional small Manx cottages i.e. low level; proposal of this size and position would also be out of keeping and detract from one of the Islands most beautiful Glens; and when entering the car park the overall impression is one of space and freedom.
5.11 The owner/occupier of Maye Cottage, Glen Maye has objected to the proposal which can be summarised as; proposed building is not suitable and would mar the image of the village and the glen; and the main road (A27) is already cluttered with parked cars and the proposal which would result in a loss of car parking would make this situation worse.
5.12 The owners/occupiers of 1 Glen Bank Cottages, Glen Maye have objected to the proposal which can be summarised as; proposed build would lead to the removal of trees contained within an established rookery and therefore detrimental to wildlife; proposed three
storey building is not in keeping with area which comprises mainly bungalows and traditional small Manx cottages; additional housing would not serve to benefit the village; reducing car parking which is already inadequate; additional parking on the A27 impacting on highway safety; three storey building would overlooking neighbouring properties; proposal would result in obstructing heavy good vehicles causing noise and disruption to local residents; the natural beauty of the glen would be destroyed.
5.13 The owner/occupier of Waterfall House, Shore Road, Glen Maye has objected to the proposal which can be summarised as; proposal result in a loss of car parking; a deed grants anyone has the right to use the car park which includes local residents, the loss of these spaces may lead to ad hoc parking in the village causing congestion and reduce visitors to the area; the existing beer garden will be a loss to visitors and local community; three storey building is out of keeping with the character and type of properties within the village; the scale and height of the proposal will create a visual scar to the tree scape and dominate the access into the glen, impacting upon the natural beauty and wildlife of the area; not aware of any discussions with local residents contrary to applicants statement; proposal will result in overlooking of my property.
5.14 The owner/occupier of 2 Glen Close, Glen Maye has objected to the proposal which can be summarised as; loss of trees due to proposal; views from the glen will be of the proposed apartments; concerns of the development being within 8 metres of the river, also where will water from storm drains go; visual impact upon the glen and waterfall; no need for more housing in Glen Maye; the three storey building is out of keeping with the village; and the loss of parking spaces which will cause highway safety concerns when travelling thorough the village.
6.1 It is considered there a number of issues which need assessing when determining this application. These are:-
a) Visual impact upon character of the village and the street scene;
b) Visual impact upon the National Glen; c) Impact upon the adjacent woodland (trees & wildlife); d) Potential amenity level for future occupants; e) Provision of car parking and potential impacts upon highway safety; and f) Potential land stability issues
6.2 Visual impact upon character of the village and the street scene
The proposal would result in a three and two storey building located within a prominent position within Glen Maye Village. When travelling through the village, along the A27 road, the majority of properties are characterised as traditional in appearance, ranging from single storey Manx cottages to two storey properties. There are more modern properties in the village, but these are generally single storey bungalows, a row of two storey terraced properties (commissioners houses) or are off the main thoroughfare (A27), located to the rear of the majority of older properties within Glen Maye. The proposal would be very apparent from a number of public viewpoints in relation to the street scene (access to car park from A27 road, within the car park, along Shore Road). The most prominent elevation seen from these locations would be a rather uninspiring collection of a blank gable end walls.
6.3 In terms of planning policy General Policy 2 paragraph b and c are the most relevant to consider. Paragraph b indicates that development will only be permitted if the proposal respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them. Paragraph c states that any development should not affect adversely the character of the surrounding landscape or townscape.
6.4 It is considered the proposal in terms of its design, scale, proportion and form makes no references to the traditional character or appearance of Glen Maye and would represent an obtrusive prominent feature detrimental to the visual amenities of the locality and the village of Glen Maye.
6.5 Visual impact upon the National Glen
As identified previously the National Glen entrance is located directly adjacent to the application site (north-western boundary). From this entrance there is a public footpath which runs down a steep slope (steps) and continues through the Glen. It should be noted that there is a considerable ground level difference between the application site and the ground level of the majority of the Glen, especially the area of open space (picnic area) which is directly to the southwest of the site. Due to this the proposal will be very apparent from various locations within the Glen, especially within the vicinity of the site.
6.6 Again General Policy 2 paragraph c is relevant to consider as development will only be permitted if it does not affect the landscape. Paragraph g also requires to be considered as this indicated that development will only be permitted if it does not affect adversely the amenity of local residents or the character of the locality.
6.7 It is considered the proposal would represent an obtrusive and towering feature detrimental to the public amenities given its scale, height, significant ground level differences, closeness to public footpaths and siting 7 metres from the south-western boundary of the site shared with the National Glen.
6.8 Impact upon the adjacent woodland (trees)
As part of the assessment the Department has asked the Forestry Division for their comments. They have responded by stating that their concern with the proposed development is that the trees located on the perimeter of the glen may be affected in the future. The close proximity of the trees in relation to the dwelling will obviously have an affect due to safety and light issues. This may result in any occupier applying to this department for a felling licence for remedial work to be undertaken and or felling of the trees.
6.9 As indicated within the representation section of this report, further concern has been raised from the Department of Environment, Food and Agricultural, due to the large trees being very close to the southern boundary of the development site which they indicated are likely to be affected. They indicated there are a total of 19 trees in the area (Monterey cypress x 2. Height c. 60ft (Rookery), Monterey pine x 3. Height c. 60 - 70ft (Rookery), Noble fir x 1 c.60ft, Oak x 1 c.60ft, Sycamore x 3 (2 x c. 40/50ft 1 x c. 60ft), Sitka spruce x 8 c. 60/70ft and Ash x 1 c. 40ft).
6.10 From visiting the National Glen it was very apparent that these trees are located directly adjacent to the south boundary of the site, but also are located on a very steep slope, some of which have their roots exposed. These trees provide an attractive backdrop not only when viewed within the National Glen, but also from the adjacent car park and the Village. It is considered they have a significant public amenity and conservation value. As the trees are within a site identified as being within 'woodland' Environment Policy 3 requires consideration. This policy indicates that development will not be permitted where it would result in the unacceptable loss of or damage to woodland areas, especially ancient, natural and semi-natural woodlands, which have public amenity or conservation value.
6.11 It is perhaps worth noting a recent appeal decision for a new dwelling within the grounds of Lorne House in Castletown (10/01644/B). The trees in this site where also protected (Environment Policy 3). The proposed single storey dwelling was also located outside the canopy spread of the nearby trees. However the Inspector commented that:-
"The present proposal has been adjusted so that the dwelling is beyond the drip line of the nearest trees. However these trees are over 13 metres high, twice the height of the proposed house. They are capable of bearing heavy summer foliage only some 3 to 4 metres from the facade and would dominate the outlook from the master bedroom, another front bedroom and the porch window lighting the hall. Although not the main living accommodation these rooms would provide a key aspect and much of the outlook for the occupants of the dwelling. I am in no doubt that the overbearing appearance of the trees and loss of light would reduce the amenity of the property significantly. The reduced amenity combined with the nuisance and anxiety caused by large trees so close to the house could amount to a justifiable case leading to the loss of the trees, which are of significant conservations value, contrary to Environment Policy 3."
6.12 These comments raise two issues; first the amenity levels of future occupants of the dwelling and due to this the potential resulting impact of the loss of the trees because a dwelling is in place. In this case the Inspector and Minister concluded that the only way to ensure the protection of the trees in the future was to refusal the dwelling. It is worth noting that the applicant for that application had undertaken a detail tree survey which indicated that the trees during construction would be unaffected by the development.
6.13 After taking further advice from the Forestry Division it has also been indicated again that the Division would not issue a felling licence for any trees in this area at the present time. However, they have indicated that if permission were to be granted they may be placed in the invidious position of having to issue a felling permit due to the close proximity of the trees in relation to the proposed building due to any future occupier being concerned with regards to their Health & Safety due to the trees close by.
6.14 Perhaps at this stage it is also worth considering the Potential amenity level for future occupants as the two issues are interlinked with each other. In this case the same issues as considered by the Inspector need assessing.
6.15 The plans do not show all the trees adjacent to the boundary, but the trees that are shown (six trees) are between 3 and 7 metres of the canopy spread. As indicated by DEFA the 19 trees in the vicinity of the boundary range from 12 to 21 metres in height (40 to 70 feet). To put into context the proposed building has a ridge height of 10 metres, whilst the highest window/balcony within the elevation facing the Glen/trees is approximately 6/8 metres above the grounds level.
6.16 The southwest elevation facing towards the National Glen/trees provides the main source of outlook and light to the kitchen and lounge areas (primary living accommodation) to all three proposed apartments (GF, 1st & 2nd floors). Furthermore, each apartment would have an individual balcony (southwest elevation) which would provide an external amenity space. It is also worth noting that there are windows within the southeast and northwest elevations which provide additional source of outlook and light for the kitchen/lounge area, but also a window for each bedroom.
6.17 It is accepted that the trees are situated below the ground level of the site, due to the topography of the adjacent land. However, given the trees substantial height, it is considered the trees would still totally dominate any outlook from any of the windows and the balcony areas of the proposed apartments, but also light to these apartments would be significantly reduced. The majority of trees are also evergreens (Monterey cypress x2, Sitka spruce x 8, Monterey pine x 3, Noble fir x 1) therefore retain the majority of their leafs (needles) throughout the year, where as the remaining deciduous trees (Oak x 1, Sycamore x 3 and Ash x 1) shed their leafs during the winter periods. Due to this foliage cover of the site, the apartment's main living accommodation would be in constant darkness throughout the year. Also whilst the suns orientation is east to west and the main source of light for the
apartments is within the southwest elevation, the substantial trees again would block any direct sun light.
6.18 The Department of Environment, Food and Agricultural also indicated in their comments that; "overhang/shading from these trees is likely to be an issue for the development as proposed. There is a rookery in the trees identified above (predominantly the Monterey cypresses and the Monterey pines). These birds can be noisy and create some mess, and might therefore be perceived as a nuisance to new residents. We would not sanction the removal of trees for these reasons. We question whether it is wise to build in a position that is likely to generate such an issue."
6.19 Consequently, for the reasons indicated it is considered the amenity standards for each apartment would be unacceptable and would be contrary to General Policy 2 paragraph h which requires any development to provide satisfactory amenity standards in itself.
6.20 Due to this amenity concern this leads back to the potential concern of the future of the adjacent trees if the proposal is permitted. As identified within paragraph 6.14, the Forestry Division have indicated that permission of the scheme may put them in the position of allowing a tree felling licence due to health and safety concerns from potential occupants of the new units. As indicated with the application for a new dwelling in the grounds of Lorne House in Castletown (10/01644/B) the Inspector and Minister concluded that the only way to ensure the protection of the trees in the future was to refusal the dwelling. It is considered due to the reduced amenity, nuisance and anxiety caused by the proximity of the proposed development to mature trees, which have public and conservation value, could result in their removal contrary to Environment Policy 3 of the Isle of Man Strategic Plan.
6.21 It should also be noted that the submission does not include any details of potential impact upon the trees and/or any tree protection measures. The Department did write to the applicant listing a number of concerns with the application, including the impact upon the woodland, but received no response.
6.22 Provision of car parking and potential impacts upon highway safety
6.23 The Isle of Man Strategic Plan identifies the required parking standards (Appendix 7) for certain developments. In this case the residential development proposed three, 2 bedroom units and a single two bedroom dwelling. Therefore the proposed development requires two off road parking spaces per unit (total of 8 spaces required). The submission indicates a total of eight spaces; however, these are not within the curtilage of the building plot, but utilising the adjacent car park, which is indicated within the submission as being with the applicant's ownership.
6.24 As part of The Department of Environment, Food and Agricultural submission they indicate that:- "The Department has the right by Deed of May 1960 to allow its visitors to the National Glen shared use of the full extent of the current car park area. No agreement has been made to vary this arrangement. It is therefore not possible to provide dedicated parking for the proposed development within the existing car park. In addition, part of the proposed garden area for the development appears to take part of the current car park. The current car park offers in the region of 50 available parking spaces and post-development would only offer between 30 and 35. The car park is regularly very busy and overflows (which we understand causes problems with local residents) and the loss of these parking spaces will inevitably have an impact upon visitors to the National Glen. This will clearly have an impact upon the tourism and amenity values of the area. In this regard, the Department feels that it must object to the proposed development as the plans currently stand."
6.25 The majority of the objectors to the proposal have also indicated concerns of loss of parking spaces due to the development and the potential over spilling of vehicles onto the main highway.
6.26 The scheme involves the moving of the existing north-eastern boundary fence approximately 0.7 metres into the existing car park area. Furthermore, to comply with current standards parking spaces for residential developments spaces are required to be 2.5m x 6m. Currently there are eight spaces along the existing fence line do not comply with this standard as they are far shorter in depth. Consequently, the proposed new spaces would project further into the existing car park, and likely affect the existing car parking spaces and lane through the car park, resulting in a loss of parking spaces contrary to Transport Policy 4 of the Isle of Man Strategic Plan. The submitted plans do not show how the proposed new spaces would be incorporated with the existing parking spaces.
Visiting the site it became very evident that the site boarders steep slopes to the sides and rear boundaries which also have a number of trees (as identified earlier in this report), which have a number of exposed roots. Further to this the proposal would be sited close to the boundaries of the site (5 metres minimum) and therefore advice was sought by the Senior Building Control Manager. He also identified that with large mature trees and bushes on the slopes any excavation could cause damage to their roots. This was a concern as he identifies that the trees in the area help with the stability of the ground in particular to sloping parts and any damage to the trees may compromise ground stability. Again concern was raised with the applicant on this issue, but not comments where received or evidence to prove that the proposal could be implemented without affecting the stability of the slope.
6.28 The Building Control Manager also advisors that the discharge of surface water drainage must be into soakaways minimum of 5 metre from any building. He indicated that this would mean a very large soakaways in the main car parking area. The suitability of ground to take surface water drainage must also be assessed. Soakaways cannot be positioned near any slopes as this causes washing of soil in the area and cause landslides. The submitted plans show the soakaways within 5 metres of a slope raising further concerns of slope stability.
6.29 Environment Policy 28 relates to unstable land. This policy indicates that development which would be at risk from ground instability or which would increase the risk from ground instability elsewhere will not be permitted unless appropriate precautions have been taken. Due to the concerns indicated it is considered as no evidence has been submitted to demonstrate the proposed development could be undertaken without having or increasing the risk from ground instability elsewhere the proposal is contrary to this policy.
7.1 It is considered that the proposal would be contrary with the relevant planning policies of The Isle of Man Strategic Plan (20th June 2007), and for the reasons set out in this report, it is recommended that the application be refused.
8.1 It is considered that the following meet the criteria of Town and Country Planning (Development Procedure) Order 2005, paragraph 6 (5) (d) and should be afforded interested party status:
The Department of Environment, Food and Agricultural (Forestry, Amenity and Lands Directorate)
The owners/occupiers of 2 The Falls, Shore Road, Glen Maye
The owner/occupier of Glenville, Glen Maye Hill, Glen Maye The owner/occupier of Hillside, Glen Maye The owners/occupiers of 1 Glen Close, Glen Maye The owner/occupier of Maye Cottage, Glen Maye The owners/occupiers of 1 Glen Bank Cottages, Glen Maye The owner/occupier of Waterfall House, Shore Road, Glen Maye The owner/occupier of 2 Glen Close, Glen Maye
8.2 It is considered that the following do not meet the criteria of Town and Country Planning (Development Procedure) Order 2005, paragraph 6 (5) (d) and should not be afforded interested party status:
The Water and Sewerage Authority The Manx Electricity Authority Environmental Protection Unit & Public Health
8.3 The Department of Transport Highways and Traffic Division is now part of the Department of Infrastructure of which the planning authority is part. As such, the Highways and Traffic Division cannot be afforded party status in this instance.
Recommended Decision: Application Withdrawn
Date of Recommendation: 26.06.2012
C : Conditions for approval N : Notes attached to conditions R : Reasons for refusal
R 1. It is considered the proposal in terms of its design, scale, proportion and form makes no references to the traditional character or appearance of Glen Maye and would represent an obtrusive prominent feature detrimental to the visual amenities of the locality and the village of Glen Maye contrary to General Policy 2 of the Isle of Man Strategic Plan.
R 2. It is considered the proposal would represent an obtrusive and towering feature detrimental to the public amenities given its scale, mass, height being positioned adjacent to and above the National Glen contrary to General Policy 2 of the Isle of Man Strategic Plan.
R 3. It is considered due to the reduced amenity, nuisance and anxiety caused by the proximity of the proposed development to mature trees, which have public and conservation value, could result in their removal contrary to Environment Policy 3 of the Isle of Man Strategic Plan.
R 4.
It is considered the proximity of the nearby substantial trees to the main living accommodation of the apartments would have significant impacts upon the residential amenities (outlook & light) of future occupants of the proposed apartments contrary to General Policy 2 of the Isle of Man Strategic Plan.
R 5. The submitted application do not adequately demonstrate that the required proposed spaces can be provided as shown, nor how the proposed new spaces would be incorporated without affecting the existing parking provision therefore contrary to Transport Policy 4 of the Isle of Man Strategic Plan.
R 6. No evidence has been submitted to demonstrate the proposed development could be undertaken without having or increasing the risk from ground instability elsewhere therefore the proposal is contrary to Environment Policy 28 of the Isle of Man Strategic Plan.
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