Officer Report
Application No.: 25/90632/C Applicant: Mr Jim Keanes Proposal: Change of use of lower ground floor to tourist accommodation, comprising 2no tourist units Site Address: Cregg Mill Silverdale Road Ballasalla Isle Of Man IM9 3DS Planning Officer: Paul Visigah Expected Decision Level: Planning Committee Recommended Decision: Permitted Date of Recommendation: 23.12.2025 _________________________________________________________________
Conditions and Notes for Approval
C : Conditions for approval N : Notes attached to conditions
- C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
- C 2. The stone-faced flood wall erected under PA 21/00778/C, as shown in the photographs submitted with the current application, shall be retained and maintained in its approved form for the lifetime of the development.
Reason: To ensure continued flood resilience and preserve the character of the Silverdale Conservation Area in accordance with Environment Policy 10 and EP35 of the Strategic Plan.
- C 3. Notwithstanding the submitted details within the Flood Systems - Flood Barrier Brochure, prior to the occupation of the tourist units, full details of the demountable flood barrier system, including a plan showing the precise locations for installation at all relevant openings, shall be submitted to and approved in writing by the Department. The approved barrier system shall then be installed in accordance with the approved details and retained thereafter for the lifetime of the development.
The tourist accommodation shall not be brought into use until these mitigation measures have been fully implemented. Reason: To provide appropriate mitigation against flooding and ensure compliance with Environment EP13 and GP 2 (l) of the Strategic Plan.
- C 4. The tourist accommodation hereby approved shall not be occupied or let between the months of October, November and December of any year.
Reason: To reduce flood risk during the months of highest rainfall, consistent with the site's location in a high-risk flood zone and in accordance with Environment Policies 10 and 13 of the Strategic Plan.
- C 5. The development hereby approved shall not be used or occupied other than for the purpose of short-let holiday accommodation and shall not be used as a separate dwelling. No guest shall occupy any part of the accommodation for a single period or cumulative periods exceeding 28 days in any calendar year.
Prior to the first occupation of the units, a management plan detailing the booking system shall be submitted to and approved in writing by the Department. The plan shall include:
- (a) the maximum permitted stay in each unit;
- (b) a system for maintaining a register of customer bookings; and
- (c) a mechanism by which the Department may inspect the register to verify compliance.
The register shall be retained for a minimum of two years from the date of the last entry and shall be made available for inspection by the Department upon reasonable request. The accommodation shall be operated strictly in accordance with the approved management plan.
Reason: To ensure the development is used solely for short-term holiday accommodation and to prevent the creation of an unjustified separate dwelling in the countryside, in accordance with Business Policy 14 and General Policy 2 of the Strategic Plan.
This application has been recommended for approval for the following reason.
The proposal represents a modest, policy-compliant refinement of an approved and partly implemented scheme. It preserves the character of the Silverdale Conservation Area, raises no significant issues in respect of parking or residential amenity, and aligns with Strategic Policy 8, Business Policies 1, 11 and 14, and Environment Policy 16 by reusing existing built fabric and supporting sustainable rural tourism. Although flood risk remains a material consideration, resilience has improved through the erection of the stone-faced flood wall and provision for a demountable barrier system. Given the site's location within a high-risk flood zone, the continuation of the seasonal occupancy restriction imposed under the previous approval remains necessary as part of a comprehensive mitigation strategy. The proposal is therefore considered compliant with the Strategic Plan.
Plans/Drawings/Information; This decision relates to the following documents and plans:
- o Applicants Statement
- o Covering Letter dated
- o Drawing No. 101 - Site Location and Site Plan
- o Drawing No. 103 - Approved and Proposed Layout Plan
- o Flood Solutions - Flood barrier System Brochure
- o Rainfall Summary
- o Cover Email and Site Photographs of new Flood Wall
- o Parking Information
- o Additional Information in Correspondence dated 10 June 2025
_________________________________________________________________ Right to Appeal
It is recommended that the following organisations should NOT be given the Right to Appeal:
- o Malew Parish Commissioners - no objections
- o DOI Highways - no objections _________________________________________________________________
Officer’s Report
THE APPLICATION IS BROUGHT BEFORE THE PLANNING COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT
1.0 THE SITE - 1.1 The site is the footprint of Cregg Mill situated within the Silverdale Complex off the Silverdale Road which links the A3 Foxdale Road to the west with Phildraw and Crossag Roads to the east, with Ballasalla village lying to the east. The complex sits at the northern end of Silverdale Glen, connected by a pedestrian route between Silverdale and Rushen Abbey with historical associations between the two. Cregg Mill is also specifically identified as worthy of consideration for Registration in the Area Plan for the South (2013). - 1.2 Cregg Mill is a three-storey stone building, formerly a mill, which sits alongside the Silverburn to the east and with additional buildings to the west and southwest. These additional buildings are later additions which provide public toilets and now a cafe and formerly a small shop with craft workshops on the lower ground floor and an ice cream making facility with viewing area on the ground floor of the Cregg Mill. - 1.3 To the south of the buildings is a small car park with another parking area to the west of the toilets. To the north of the buildings is a small boating lake and play equipment including an historic water powered roundabout run by a small mill race alongside. The area sits in the middle of a glen with pedestrian walks northwards towards Athol Bridge and southwards towards Rushen Abbey. There is a small number of residential properties near the site Silverdale lies around 40m to the east and Mill House approximately the same distance away to the southwest with Silverdale House alongside, slightly further away. Towards the western end of Silverdale Road lies Creg Mill Lodge, close to the junction with the A3.
2.0 THE PROPOSAL - 2.1 Planning approval is sought for Change of use of lower ground floor to tourist accommodation, comprising 2no tourist units. This proposal is similar to the proposal approved under PA 21/00778/C, with the key change being the change in layout. - 2.2 The proposed layout represents a significant shift from the approved arrangement. The approved plan was designed as a shared accommodation model, featuring a communal area, dining space, and a single kitchen serving three individual bedrooms with ensuite arranged along a corridor. In contrast, the proposed layout removes the communal and shared facilities and instead introduces two self-contained units, each with its own lounge, kitchenette and wet room, creating independent living spaces. This change reduces shared social areas and alters the internal circulation pattern, moving from a lodge-style configuration to a more segmented layout focused on privacy and autonomy. The inclusion of the watch wheel mechanism as a central feature remains, but the overall functional emphasis transitions from group use to separate, self-contained occupancy. The applicant states that the conversion will improve insulation and heating efficiency, which will help preserve the historic fabric of the building and contribute to its long-term viability. - 2.3 The physical changes to the building are all internal, evidenced through the introduction of stud walling to create the new accommodation. There would be no external alterations to the building.
2.4 The provided Cover Email indicates the following:
- 1. Planning approval was granted for three tourist accommodation units on the lower floor of Cregg Mill.
- 2. Building works commenced approximately 18 months after the initial approval.
- 3. At the start of construction, it became clear that three units would not provide the level of comfort expected by guests.
- 4. The decision was therefore made to create two fully self-contained units, each offering an improved layout for customer satisfaction and experience.
- 5. As the area already had permission for tourist accommodation, the change was made without full consideration of the original conditions, largely due to the time lapse between approval and commencement.
- 6. The revised layout is intended to enhance the customer experience while reducing overall occupancy.
2.5 On parking, the applicant has provided information which indicates that a new car park was constructed approximately four years ago. This facility provides two coach parking bays and forty car spaces. The lower car park adjacent to the existing facilities is used primarily as a drop-off point, with visitors then parking in the new car park and walking down to the accommodation via a pedestrian access. - 2.6 The Following supporting information details flood mitigation for the site:
- 1. Provision of Photographs to show that Flood wall which was required as part of mitigation for the scheme for PA 21/00778/C under Condition 5, with material controlled by Condition 2 is now insitu.
- 2. A Flood Barrier Systems Brochure by Lakeside Flood Solutions which provides the following information: a. The demountable aluminium flood barrier system that has been tested internationally to
- a height of 2.1m with zero leakage, exceeding the British Kitemark standard (which only certifies up to 600mm and allows leakage in three places).
- b. Features include ground U-channel for a continuous watertight seal, no tools required for installation, and robust yet lightweight anodized aluminium construction.
- c. The system has no width or height limitation, is maintenance-free, and comes with a two-year guarantee.
- d. Proven performance: Lakeside barriers have protected over 300 homes and businesses in major flood protection schemes in the UK.
- 3. Rainfall Data for the Isle of Man (Ronaldsway Station) which shows the following:
- a. Annual Climate Profile: The Isle of Man experiences an average annual rainfall of 884.8 mm, spread across approximately 192 rain days (greater than 0.1 mm) and 143 wet days (greater than 0.9 mm), alongside an annual sunshine total of 1,628.7 hours.
- b. Seasonal Variation: Rainfall is highest in autumn, with October (103.0 mm) and November (105.3 mm) being the wettest months, while April (54.4 mm) and May (54.7 mm) are the driest. This pattern highlights the need for flood resilience measures to be most robust during the autumn period.
- c. Extreme Events: Historic records show significant variability, including a wettest month of 237.1 mm (January 1948), a driest month of 1.5 mm (February 1986), and a wettest day of 75.1 mm (21 October 2002). Sunshine extremes range from 327.0 hours (July 1955) to 17.7 hours (December 1977), illustrating the potential for intense rainfall events.
2.7 A Statement from the applicant details the following:
- 1. Cregg Mill comprises three floors; the upper two floors are currently let to Trail Lodge Limited for tourist accommodation. The business commenced in December 2019 following planning approval granted in July 2017.
- 2. Planning permission was previously granted for three tourist accommodation units on the lower ground floor, but prior to construction it was determined that the rooms would be too small for the level of comfort expected. The revised proposal seeks to create two fully selfcontained units to maintain five-star accreditation achieved in previous conversions.
- 3. Each unit will accommodate up to two people, resulting in a net increase of only four extra persons per night across the whole property.
- 4. The change of use will improve insulation and heating, helping to preserve the materials and historic fabric of the building.
- 5. The lower ground floor benefits from two parking spaces near the entrance. Relocation of the former ice cream manufacturing facility will eliminate coach tours, reducing parking pressure and improving conditions for neighbouring properties.
- 6. The property is located on the bank of the Silverburn River and was originally constructed circa 1823 for corn milling by monks at Rushen Abbey. A five-metre water wheel on the north elevation has been refurbished to generate renewable energy for the tourist accommodation.
- 7. Only one high-water event has occurred in the past ten years, during severe Islandwide flooding in December 2015, when water did not reach the entrance of the lower floor. The lower floor is approximately two metres above the current river level.
- 8. A Manx stone flood wall has been erected following previous consultations, designed to protect against the predicted 1-in-100-year climate change level as advised by the Flood Risk Management Division. The lower ground floor has not experienced flooding to date, even during the highest recorded event in 2015.
3.0 PLANNING POLICY - 3.1 The site, along with the buildings, boating pond and play area, lies within an area designated on the Area Plan for the South as Tourism, and the site is also within the Silverdale Conservation Area, although it sits in the countryside being without the settlement boundary of Ballasalla. Silverdale, along with Rushen Abbey and Ballasalla are identified as some of the many tourist attractions in the area. Creg Mill is identified as a building worthy of consideration for Registration (Appendix 5). The eastern section of the site is considered to be prone to high fluvial and surface water flood risks. The site is not within a registered tree area and there are no registered trees on site. - 3.2 Due to the zoning of the site and the proposed works the following policies are relevant in the determination of the application:
- 1. General Policy 2 - General Development Considerations.
- 2. General Policy 3 - Exceptions to development in the countryside.
- 3. Spatial Policy 5 - new development will be in defined settlements only or in the countryside only in accordance with GP3.
- 4. Business Policy 1 - Supporting economic growth through business developments that benefit local employment and sustainability.
- 5. Business Policy 11 - Tourism development must be in accordance with the sustainable development objectives of this plan; policies and designations which seek to protect the countryside from development will be applied to tourist development with as much weight as they are to other types of development.
- 6. Business Policy 12 - Permission will generally be given for the conversion of redundant buildings in the countryside to tourist use providing that the development complies with the policies set out in paragraph 8.10. - Housing Policy 11.
- 7. Business Policy 14 - Tourism development may be permitted in rural areas provided that it complies with the policies in the Plan.
- 8. Strategic Policy 1 - Efficient use of land and resources.
- 9. Strategic Policy 2 - Priority for new development to identified towns and villages.
- 10. Strategic Policy 4 - development proposals must protect or enhance the nature conservation and landscape quality of urban as well as rural areas.
- 11. Strategic Policy 5 - Design and visual impact.
- 12. Strategic Policy 10 - Development should be located and designed to promote an integrated transport network, minimising private car use, making best use of public transport, ensuring highway safety, and encouraging pedestrian movement.
- 13. Environment Policy 1 - Protection of the countryside and inherent ecology.
- 14. Environment Policy 7 - Development that would cause demonstrable harm to a watercourse, wetland, pond or dub and cannot be mitigated will not be permitted. Where works affect a watercourse, applications must identify all watercourses and include a risk assessment to show no long-term deterioration in water quality, provide details of pollution and alleviation measures, and phase engineering works to avoid reducing water quality. Normally, development will not be allowed within 8 metres of any watercourse to protect aquatic and bankside habitats and species.
- 15. Environment Policy 10: Where development is proposed on any site where in the opinion of the Department of Local Government and the Environment there is a potential risk of flooding, a flood risk assessment and details of proposed mitigation measures must accompany any application for planning permission. The requirements for a flood risk assessment are set out in Appendix 4.
- 16. Environment Policy 13 - Development which would result in an unacceptable risk from flooding, either on or off-site, will not be permitted.
- 17. Environment Policy 16 - The reuse of existing rural buildings for new purposes such as tourism or small-scale industrial/commercial use may be permitted where the building is no longer required for its original function, is substantially intact, and structurally capable of renovation. Proposals must preserve fabric of historic, architectural, or social interest, avoid extensions or adverse changes to character, and demonstrate no unacceptable traffic implications or dispersal of activity that undermines town or village vitality. Where significant redevelopment is involved, environmental and rural economy benefits must outweigh the impact of retaining the building. Residential conversions will be assessed in accordance with guidance in Section 8.10.
- 18. Environment Policy 35 - Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area, and will ensure that the special features contributing to the character and quality are protected against inappropriate development.
- 19. Transport Policy 1 - Proximity to existing public transportation services.
- 20. Transport Policy 4 - New and existing highways serving development must be designed to safely and appropriately accommodate the vehicle and pedestrian journeys generated by that development, while meeting the environmental objectives of the plan.
- 21. Transport Policy 7 - The Department will require that in all new development, parking provision must be in accordance with the Department's current standards. Appendix 7: Hotels, motels, guest houses - 1 space per guest bedroom (In rural and suburban locations).
- 22. Community Policy 7 - Designing out criminal and anti-social behaviour.
3.3 The following tourism related policies are considered relevant:
- 1. Strategic Policy 8 - 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 manmade attractions.
- 2. Paragraphs 9.5.7: "Although previous Local Plans have applied a "Tourism" designation to areas with a large number of hotels, such a designation is becoming less appropriate in many towns and villages as the reduced demand for larger Victorian hotels results in conversion to private residential use. It is now more likely that a Tourism designation be given to specific tourist attractions and existing large individual hotel sites, with new tourist accommodation incorporated into areas of mixed or residential use. Wider areas which still include a large tourism element, such as Douglas Promenade, may be designated for "Residential/ Tourism" use (other potential uses may be identified and included in a mixed designation if appropriate).
- 4.0 OTHER MATERIAL PLANNING CONSIDERATIONS
4.1 Policy on the Development of Non-Serviced Accommodation 2019.
- 4.1.1 This document is an offshoot of the Isle of Man Non-Serviced Accommodation Futures Final Report (2017). It sets out governments priorities as it relates to tourism, provides a summary of the non-serviced study, whilst also outlining the current visitor economy strategy, in addition to articulating the Island Policy towards tourism development.
4.2 Isle of Man Visitor Economy Strategy 2022-2032
- 4.2.1 The Strategy's headline targets are to grow the annual visitor numbers to 500,000 by 2032 and increase the annual economic contribution of the Island's Visitor Economy to £520m. This will mean attracting an additional 170,500 visitors per year compared to 2019. The aim is to triple the holiday and short break market as well as grow all of the other visitor markets. Combined with an expected increase in average spending per visitor, driven by strong growth in longer staying and higher spending leisure markets, these visitor numbers should result in a more than doubling of annual visitor spending on the Island to £310m, which will support an increase in Visitor Economy jobs to 5,000 and generate an annual Exchequer benefit of £49m.
- 4.2.2 Programme 3: Visitor Accommodation Transformation A key aspiration is to widen our non-serviced accommodation supply with the introduction of the innovative offers that are finding a strong market in competitor destinations, such as backto-nature retreats, lifestyle and wellness resorts, sea cabins, treehouses, sky huts and luxury glamping sites.
4.3 Planning Policy Statement (PPS): Planning & the Economy (A Consultation Document February 2012)
- 4.3.1 "In applying the provisions of the Strategic and Area Plans, particularly General Policy 1 and General Policy 3 of the Strategic Plan, the Department will seek proposals to be supported by evidence that demonstrates that the proposed development would secure sustainable, long term economic growth of Island wide benefit, which meets the wider objectives of sustainable development by weighing market and other economic matters alongside environmental and social costs and benefits."
4.4 Planning Policy Statement 1/01 - Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man
- 4.4.1 POLICY CA/2 - SPECIAL PLANNING CONSIDERATIONS When considering proposals for the possible development of any land or buildings which fall within the conservation area, the impact of such proposals upon the special character of the area, will be a material consideration when assessing the application. Where a development is proposed for land which, although not within the boundaries of the conservation area, would affect its context or setting, or views into or out of the area; such issues should be given special consideration where the character or appearance of a conservation area may be affected.
- 5.0 PLANNING HISTORY
5.1 The most recent planning application for the site is considered to be specifically relevant to the current application:
5.2 Planning approval was granted under PA 21/00778/C for Change of use of lower ground floor to tourist accommodation. This was approved on 19th October 2022. This approval was subject to seven approval conditions which are detailed below:
- 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
- 2. Notwithstanding the submitted plans, the proposed flood wall shall be similar to the existing stone walls on the site in terms of its shape, colour, size and thickness.
Reason: To ensure that the flood wall detailing preserves the appearance and character of the Silverdale Conservation Area and to ensure that the new wall ties in with the existing walls to which it would be attached.
- 3. No works in connection with the development hereby approved shall commence until details of proposed construction materials showing, including the colour, texture, bond and pointing of any stonework and render and manufacturer's specification for the flood barrier system have been submitted to and approved in writing by the Department.
Reason: In the interests of the appearance of the development and the visual amenities of the area.
- 4. The development hereby approved shall not be used or occupied other than for the purpose of short-let holiday accommodation and shall not be used as a separate dwelling. The accommodation hereby approved shall not be occupied by the same person(s) for a single period or cumulative periods exceeding 28 days in any calendar year.
Reason: To ensure that the development is only used and occupied as short let holiday accommodation and to prevent the creation of an unjustified separate dwelling in the countryside.
- 5. The development hereby approved shall be carried out in strict accordance with the submitted Flood mitigation scheme detailed in the Planning Statement, Correspondence in Cover Email dated 21 June 2022, Proposed Plans and Sections received 12 April 2022, and the Lakeside Flood Solutions Brochure, and shall be retained thereafter. The tourist accommodation shall not be brought into use until these mitigation measures have been fully implemented.
Reason: To provide appropriate mitigation against flooding and to ensure that flood vulnerability for the site is not exacerbated by the development.
- 6. The tourist accommodation hereby approved shall not be occupied or let between the months of October, November & December of any year.
Reason: To ensure proper control of the development and to reflect the information provided in the application, as the Department has assessed the impact of the proposal on the basis of the specific use and the documents submitted.
- 7. The development hereby approved shall be carried out only in accordance with the following drawings and documents: Drawings 01, 02, 03 received 24 June 2021 Drawings A01, A02 received 12 April 2022 Flood Barrier Systems brochure received 1 July 2022 Reason: For the avoidance of doubt and in the interests of proper planning.
5.3 The site was also the subject of a tourism application under PA 17/00405/B for Conversion of existing store / retail / craft areas to provide tourist living accommodation Approved. This was a Department Application. The Case Officer, in recommending approval, noted that the proposal would secure a viable use for an underutilised building within the Silverdale complex, consistent with its tourism designation and Environment Policy 16, and that the conversion would complement existing attractions without causing unacceptable impacts on parking, highway safety, or residential amenity.
- 6.0 REPRESENTATIONS
Copies of representations received can be viewed on the government's website. This report contains summaries only.
6.1 DOI Highways Division find the proposal to have no significant negative impact upon highway safety, network functionality and/or parking as the proposed use would have a similar parking demand to the existing approved use, and there is public parking available for visitors in the Silverdale Glen area (30 June 2025).
6.2 Malew Parish Commissioners have no objection to the application (3 July 2025).
6.3 The Following Statutory Consultees have not made any comments on the application although they were consulted on 26.06.2025 and 21.11.2025:
- 1. DOI Flood Risk Management
- 2. Manx Utilities Authority - Drainage
- 3. Manx National Heritage
- 4. DEFA Inland Fisheries
- 5. Registered Buildings Officer
- 6.4 No comments have been received from neighbouring properties.
- 7.0 ASSESSMENT
7.1 The fundamental issues to consider in the assessment and determination of this application are:
- 1. The principle of the proposed scheme;
- 2. The Visual impact of the proposal on the existing property and the surrounding area;
- 3. Issues with parking;
- 4. The impact of the proposal upon nearby neighbouring properties; and
- 5. Flood concerns.
7.2 STATUTORY TEST - Section 18 (4)
- 7.2.1 In accordance with Section 18(4) of the Act, it is considered that the proposal does not conflict with the objectives set out therein. The application has therefore been assessed in the context of the relevant policies identified below and within Sections 3 and 4 of this report.
- 7.3 THE PRINCIPLE (SP 8, BP 1, 11, 14 & EP 16)
- 7.3.1 In considering the principle of converting the lower ground floor of Cregg Mill to two self-contained tourist units, the starting point is the Area Plan for the South, which designates the site for Tourism. This designation establishes a strong presumption in favour of touristrelated development, provided that proposals comply with the wider strategic and environmental policies of the Plan. The principle of tourist accommodation at this location is well established: planning approval was first granted under PA 17/00405/B for the conversion of existing store and craft areas to tourist living accommodation, and subsequently under PA 21/00778/C for three tourist units on the lower ground floor. Both approvals recognised that the reuse of this underutilised building within the Silverdale complex was consistent with its tourism designation and Environment Policy 16, and that such conversion would complement existing attractions without causing unacceptable impacts on parking, highway safety or residential amenity.
- 7.3.2 The current proposal does not introduce a new land use but seeks to amend the internal layout of the previously approved scheme, replacing three shared units with two fully self-contained units. This refinement responds to operational experience and customer expectations, aiming to improve comfort and privacy while reducing overall occupancy. By doing so, the proposal continues to meet the objectives of Strategic Policy 8, which supports tourist development where it makes use of existing built fabric of interest and quality and enables enjoyment of natural and man-made attractions without adverse environmental or highway impacts. Cregg Mill is a building identified as worthy of registration and sits within the
- Silverdale Conservation Area, adjacent to the Silverburn River and connected to the Silverdale Glen and Rushen Abbey walks. Reusing this historic structure without external alteration safeguards its character while enhancing the visitor experience in a location that is already a focal point for tourism.
- 7.3.3 Environment Policy 16 reinforces this position by permitting the reuse of rural buildings for tourism where they are no longer required for their original purpose, are structurally capable of renovation, and where such reuse preserves historic fabric without adverse change to appearance or character. Cregg Mill meets these criteria: it is no longer used for milling, is substantially intact, and the proposed works are confined to internal stud walling, avoiding any external impact. The policy also requires that conversions do not create unacceptable traffic implications or disperse activity to a scale that undermines the vitality of existing settlements. The reduction from three units to two ensures that the proposal will not generate significant traffic or erode the role of Ballasalla as the nearest service centre.
- 7.3.4 Business Policies 1, 11 and 14 further support the scheme by promoting economic growth through tourism development that is sustainable and respectful of the countryside. Policy 11 makes clear that tourism proposals must be assessed with the same rigour as other forms of rural development, ensuring that countryside protection objectives are upheld. Policy 14 specifically encourages quality self-catering accommodation in rural buildings, provided it complies with the Plan's policies. The current proposal achieves this by making efficient use of an existing building rather than introducing new built form into the countryside. This approach aligns with the Isle of Man Visitor Economy Strategy 2022-2032, which seeks to broaden the range of non-serviced accommodation and attract higher-spending leisure markets through distinctive, high-quality offers in rural settings.
- 7.3.5 Accordingly, the principle of development is considered acceptable when assessed against the relevant policies and material considerations. It represents a sustainable form of rural tourism development that preserves the historic character of Cregg Mill, supports the local economy, and complies with SP 8, BP 1, BP 11, BP 14 and EP 16.
7.4 VISUAL AND CHARACTER IMPACTS (GP2, STP 4 and 5, EP 35 & PPS 1/01)
- 7.4.1 The key issue in this case is whether the proposal would adversely affect the building or the character and appearance of the Silverdale Conservation Area. The works are entirely internal, involving stud walling to create two self-contained units, and therefore will not alter the external appearance of the building. The previously approved flood wall has been constructed in stone to match existing walls, ensuring visual continuity and preserving the character of the site.
- 7.4.2 By securing a viable use for the building, the proposal also helps maintain its condition and prevents deterioration, which indirectly supports conservation objectives. For these reasons, the scheme is considered to preserve the character and appearance of the Conservation Area and complies with EP35, PPS 1/01 and Strategic Policies 4 and 5.
7.5 PARKING PROVISIONS (GP 2, SP 10 and TP7)
- 7.5.1 In terms of parking, the conversion to two tourist units is unlikely to generate demand beyond that associated with the previously approved three-unit scheme. The site benefits from a large car park constructed approximately four years ago, providing 40 spaces and two coach bays, supplemented by a drop-off area adjacent to the building. The applicant confirms that visitors typically use this facility and access the accommodation via a pedestrian route.
- 7.5.2 The site is also within short walking distance of public transport services along the A3 corridor, reducing reliance on private cars. Furthermore, DOI Highways has raised no objection, confirming that the proposal will have no significant impact on highway safety or network functionality. Accordingly, the scheme meets the requirements of GP2, SP10 and TP7.
7.6 IMPACT ON NEIGHBOURS (GP 2 & BP 11) 7.6.1 In assessing potential impacts on neighbours, it is considered that the property is already in use for tourist accommodation, and the revised layout reduces overall occupancy compared to the previously approved scheme. It is also worth noting that the nearest dwellings are approximately 40 metres away, and the intervening landscape and existing activity levels within the Silverdale complex provide a buffer against any potential impacts.
7.6.2 Moreover, no objections have been received from neighbouring properties, and Malew Parish Commissioners have raised no concerns. The proposal is therefore considered to have no adverse effect on residential amenity and complies with GP2 and BP11.
7.7 FLOOD CONCERNS (GP2, EP 10 and EP 13)
- 7.7.1 With regard to potential flood impacts, the eastern boundary of the site where the proposed tourist units would be located lies within a high fluvial and surface water flood risk zone. Unlike the previous application, no updated Flood Risk Assessment has been submitted with this proposal, which represents a departure from the expectation under Environment Policy 10 that such assessments accompany development in areas of potential flood risk. While this omission weighs against the scheme, the Department must consider the context: the principle of tourist accommodation on this floor was previously accepted under PA 21/00778/C, and the site circumstances have not changed.
- 7.7.2 Importantly, the mitigation measures that were central to the previous approval have now been partially implemented. The stone-faced flood wall required under PA 21/00778/C has been erected, providing a significant improvement in resilience compared to the position at the time of the earlier decision. Previously, it was anticipated that in an extreme 1-in-100-year plus climate change event, water levels could exceed 1 metre within the building. The new wall, which sits over 1 metre above the previous threshold, substantially reduces this risk while being designed to integrate visually with the existing stonework, preserving the character of the Silverdale Conservation Area. This enhancement means the site is now better protected than when the previous scheme was approved.
- 7.7.3 The demountable barrier system referenced in the earlier approval has not yet been installed, meaning that resilience currently relies on the flood wall rather than a full suite of physical defences. While the wall provides a significant improvement, it was originally conceived as part of a broader package of measures, including operational controls, to address the vulnerability of lower ground floor accommodation in a high-risk flood zone. The location remains subject to extreme rainfall events, and short-let tourist use introduces residual risk during periods historically associated with the highest rainfall. For this reason, the Department considers that the seasonal occupancy restriction imposed under PA 21/00778/C remains necessary as part of a comprehensive mitigation strategy.
- 7.7.4 On balance, while the absence of a new Flood Risk Assessment weighs against the proposal, the completed flood wall represents a material improvement over the previous position, and the ability to condition the barrier system alongside the continuation of the seasonal occupancy restriction provides a robust mitigation package consistent with the approach taken under the earlier approval. These measures reduce risk to a level that is proportionate for short-let tourist use rather than permanent residential occupation. Subject to conditions requiring retention of the flood wall, installation of the barrier system, and adherence to the seasonal restriction, the proposal is considered to comply with the intent of EP10 and EP13. Overall, flood risk remains a material consideration but does not amount to a sufficient reason for refusal when balanced against the benefits of the development, its contribution to the visitor economy, and the absence of significant adverse impacts on visual amenity, highway safety or neighbouring properties.
- 8.0 CONCLUSION
8.1 The proposal is a modest, policy-compliant refinement of an already approved scheme, reducing occupancy while improving guest comfort and privacy within an existing building of historic interest in a designated Tourism zone. The site context remains unchanged, and the development continues to preserve the character of the Silverdale Conservation Area without introducing external alterations. Parking and residential amenity impacts are negligible, and the position on flood risk is improved over the previous approval: the required stone-faced flood wall has been erected, and full details of the demountable barrier system have been resubmitted, enabling its installation to be conditioned. Given the site's location within a highrisk flood zone, the continuation of the seasonal occupancy restriction imposed under the previous approval remains necessary as part of a comprehensive mitigation strategy. These measures provide proportionate mitigation for short-let tourist use. When balanced against the benefits of sustaining rural tourism, reusing existing built fabric, and supporting the visitor economy, the proposal is considered acceptable and is recommended for approval, subject to conditions securing flood resilience and occupancy controls. - 9.0 RIGHT TO APPEAL AND RIGHT TO GIVE EVIDENCE
9.1 The Town and Country Planning (Development Procedure) Order 2019 sets out the process for determining planning applications (including appeals). It sets out a Right to Appeal (i.e. to submit an appeal against a planning decision) and a Right to Give Evidence at Appeals (i.e. to participate in an appeal if one is submitted).
9.2 Article A10 sets out that the right to appeal is available to:
- o applicant (in all cases);
- o a Local Authority; Government Department; Manx Utilities; and Manx National Heritage that submit a relevant objection; and
- o any other person who has made an objection that meets specified criteria.
9.3 Article 8(2)(a) requires that in determining an application, the Department must decide who has a right to appeal, in accordance with the criteria set out in article A10. - 9.4 The Order automatically affords the Right to Give Evidence to the following (no determination is required):
- o any appellant or potential appellant (which includes the applicant);
- o the Department of Environment, Food and Agriculture, the Department of Infrastructure and the local authority for the area;
- o any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and
- o in the case of a petition, a single representative.
I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to that body by the appropriate DEFA Delegation and that
in making this decision the Committee has agreed the recommendation in relation to who should be afforded interested person status and/or rights to appeal.
Decision Made: Permitted Date: 26.01.2026 Signed : Mr Paul Visigah Presenting Officer
Customer note This copy of the officer report reflects the content of the office copy and has been produced in this form for the benefit of our online service/ customers and archive record.
Planning Committee Decision 26.01.2026
Application No. : 25/90632/C Applicant : Mr Jim Keanes Proposal : Change of use of lower ground floor to tourist accommodation, comprising 2no tourist units Site Address : Cregg Mill Silverdale Road Ballasalla Isle Of Man IM9 3DS Presenting Officer : Paul Visigah Addendum to the Officer’s Report
The Planning Committee considered the application at its meeting on 26th January 2026 and agreed with the recommendation to approve the application subject to the removal of Condition 4, which read:
The tourist accommodation hereby approved shall not be occupied or let between the months of October, November and December of any year.
Reason: To reduce flood risk during the months of highest rainfall, consistent with the site's location in a high-risk flood zone and in accordance with Environment Policies 10 and 13 of the Strategic Plan.
The application was therefore approved without the above condition. _____________________________________________________________________________