Planning Statement Dated

·

TOWN AND COUNTRY PLANNING ACT 1999

TOWN AND COUNTRY PLANNING (DEVELOPMENT PROCEDURE) ORDER 2019

Planning Statement

FEBRUARY 2025 REVISION A (MAY 2025) APPLICATION REFERENCE: 25/90196/B PROPOSAL: FULL APPLICATION FOR 14 BUNGALOWS, INCLUDING VEHICULAR ACCESS ADDRESS: LAND ADJACENT TO GINGER HALL HOTEL, SULBY

Architecture.im Limited, trading as arc.im Company Number 135236C (Isle of Man) Directors: E. P. H. CRAINE, J. F. CRAINE Reg. Office: Mwyllin Squeen, Ballaugh, I.o.M. IM7 5AH

+44(0)76 2422 2422

architecture.im [email protected]

• 0.0 CONTENTS

• 1.0 Introduction ............................................................................................................... 3
• 2.0 Planning History ......................................................................................................... 4
• 3.0 The Site and its Surrounding ........................................................................................ 5
• 4.0 Development Proposal and Design .............................................................................. 6
• 5.0 Housing Mix .............................................................................................................. 7
• 6.0 Public Open Space and Local Area for Play ................................................................. 8
• 7.0 Ecology and Landscaping ........................................................................................... 9
• 8.0 Arboricultural Impact ................................................................................................ 10
• 9.0 Drainage and Flood Risk ........................................................................................... 11
• 10.0 Energy Conservation ................................................................................................. 11
• 11.0 Highways, Access and Parking ................................................................................... 13
• 12.0 Summary and Conclusions ........................................................................................ 15

• 0.1 DEFINITIONS

Act ....................................................................... Town and Country Planning Act 1999 Agent ......................................................................................... Architecture.im Limited AOD .................................................................... Above Ordnance Datum (Douglas02) Applicant ............................................................................................... Foxfield Limited Application .................... this application, put before DEFA for determination under the Act Area Plan ........................................... the Sulby Local Plan 1999 (Planning Circular 1/99) Extant Approval ........................... the planning approval under reference PA 22/01112/B DEFA .......................... Department of Environment, Food and Agriculture (of the IOMGov) DoI ............................................................ Department of Infrastructure (of the IOMGov) Development Plan .......................................... the IMSP and the Area Plan in combination DPO ........................... Town and Country Planning (Development Procedure) Order 2019 HSDC .......................................... Highway Services Development Control division of DoI IMSP ........................... the Isle of Man Strategic Plan 2016 – Towards a Sustainable Island IOMGov ............................................................................. the Isle of Man Government LAP ................................................................................................. Local Area for Play Local Authority ................................................................. Lezayre Parish Commissioners MfMR ............................................................................. Manual for Manx Roads, 2021 PABC ........... the planning authority, the Planning and Building Control Directorate of DEFA POS ................................................................................................ Public Open Space PROW ............................................................................................. Public Right of Way Proposal ................................................. the development as proposed in the Application Site ....................................................................... the land that the Application concerns Statement ...................................................... this document, together with its appendices

• 1.0 INTRODUCTION

• 1.1 IMSP (§4.3.11) Strategic Policy 5:—

New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases [DEFA] will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies.

• 1.2 This Statement is presented on the Applicant’s behalf in support of a detailed planning application for the development of fourteen residential bungalows, with associated infrastructure, upon vacant land adjacent to the Ginger Hall Hotel, Sulby. It should be read in conjunction with all supporting submissions.
• 1.3 The Application responds to a pressing need for affordable housing in the Island which, driven also by IOMGov’s economic strategy, has intensified demand for land.
• 1.4 While the Site already benefits from an Extant Approval for seven dwellings, preapplication consultation with PABC elicited positive feedback, which has constructively informed this Proposal’s design.
• 1.5 This Proposal will provide units eligible for first-time home buyers’ assistance, Public Open Space and a Local Area for Play, going beyond the Extant Approval’s provisions.
• 1.6 In summary, the Proposal ensures more efficient use of land for its designated purpose.

• 2.0 PLANNING HISTORY

• 2.1 The following planning cases relate to the Site:—

• • PA 09/00504/B ........................................................................ approved 12/05/2010 Detailed four-dwelling scheme
• • AP 10/0071 ....................................................................... appeal upheld 23/09/2010 Appeal against the approval of PA 09/00504/B
• • PA 11/00155/B ........................................................................... refused 01/04/2011 Detailed four-dwelling scheme
• • PA 12/01125/B ........................................................................... refused 29/01/2013 Detailed six-dwelling scheme
• • PA 13/91035/B ........................................................................... refused 02/06/2014 Detailed five-dwelling scheme
• • AP 14/0037 ................................................................... appeal dismissed 14/08/2014 Appeal against the refusal of PA 13/91035/B
• • PA 14/01198/B ........................................................................ approved 03/07/2015 Detailed five-dwelling scheme
• • PA 17/00462/B ........................................................................ approved 13/02/2017 Detailed seven-dwelling scheme
• • AP 18/0009 .................................................................. appeal dismissed 19/07/2018 Appeal against the approval of PA 17/00462/B
• • PA 22/01112/B ........................................................................ approved 09/05/2024 Resubmission of PA 17/00462/B with amendments

• 2.2 The Site has been designated as Predominantly Residential since 1982, following the implementation of the previous area plan. It is identified as Development Area 5 in the current Area Plan, adopted in 1999. Since the introduction of this plan, several applications have been submitted proposing various layouts and house types.
• 2.3 The IMSP, first adopted in 2007 and amended in 2016 to address increased housing needs, established the current Development Plan. The Act §2(4):—

The proposals in an area plan shall be in general conformity with the strategic plan; but in case of any inconsistency between the provisions of the strategic plan and the provisions of an area plan, whichever came into force later shall prevail.

• 2.4 A seven-dwelling scheme was initially approved in 2017 and later challenged on appeal, which helped clarify key considerations such as highway safety, drainage provision, biodiversity mitigation, and tree protection. The appeal was ultimately dismissed by the Minister for DEFA and the approval was confirmed.

• 2.5 The seven-dwelling scheme was resubmitted, and later approved in 2024, extending the four-year commencement period to 2028. Amendments included updated highway details to meet new MfMR requirements, the removal of a garage encroaching into a tree’s root protection area, a drainage plan incorporating stormwater attenuation, and a biodiversity scheme developed with DEFA’s Ecosystem Policy Team.

• 3.0 THE SITE AND ITS SURROUNDINGS

• 3.1 The Site is an irregularly shaped grassy field measuring 5425m2 horizontally, formerly part of a larger rectangular parcel that also included the adjacent Ginger Hall Hotel.
• 3.2 The Site is bordered:—

NW to the northwest by four bungalows, each south of Carrick Park’s access road — The Shop is closest to and directly accessed from the A3 highway, while Nos. 41, 40, and 39 Carrick Park are positioned progressively farther from the junction;

NE to the north east by the A3 highway, the hotel’s car park, and the hotel itself; SE to the south east by an area of mature trees to the hotel’s rear; and SW to the south west by two bungalows, both served by Ballamanagh Close — Esfahan,

closest to Yn Claddagh (the B8 highway), and Glion, farther from it

• 3.3 The difference in ground levels across the Site is reflected in the adjacent highways’ levels. The A3 is at 15.20m AOD adjacent to the northern corner, while Yn Claddagh is at 19.32m AOD adjacent to the southern corner (a 4.12m level difference).
• 3.4 A drainage ditch runs along the northwest edge of the Site, with the ground sloping towards the northern corner, where surface water is directed into several pipes.
• 3.5 A bus stop is located adjacent to the A3 highway, next to the Site’s north corner.
• 3.6 The Site is fenced for the most part, also with sod banks adjacent to both highways. Some fencing has, however, been damaged by recent storms (Darragh and Eowyn).
• 3.7 In its broader context, the Site lies within a more recently developed part of Sulby village. The older parts, located at the far end of Yn Claddagh (near its junction with the Tholt-y-Will road) and along the A3 (west of Sulby Bridge) feature relatively cohesive collections of stone buildings. In contrast, east Sulby comprises a more varied built environment, with differing scales, styles, and densities, resulting in less uniformity.
• 3.8 Sulby benefits from a primary school, a community hall, two public houses, a Methodist church (currently being refurbished), an Anglican church, the Claddagh common land, and many attractive recreational PROWs into the uplands and northern plain.

• 4.0 DEVELOPMENT PROPOSAL AND DESIGN

• 4.1 IMSP (§6.2) General Policy 2:—

Development which is in accordance with the land-use zoning […] will normally be permitted, provided that the development […]

• (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them;
• (c) does not affect adversely the character of the surrounding landscape or townscape;[…] (g) does not affect adversely the amenity of local residents or the character of the locality;[…]

• 4.2 IMSP (§4.2.1) Strategic Policy 1:—

Development should make the best use of resources by:

• (a) optimising the use of previously developed land, redundant buildings, unused and under-used land and buildings, and reusing scarce indigenous building materials;
• (b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space and amenity standards; and
• (c) being located so as to utilise existing and planned infrastructure, facilities and services.

• 4.3 The Proposal includes a mix of low-cost housing in various forms and configurations. While the number of dwellings has increased from the Extant Approval, the massing remains largely consistent with what was previously deemed acceptable, considering both the larger house types and detached garages.
• 4.4 A plan showing the footprints of the dwellings from the Extant Approval overlaid on the Proposal is provided (drawing 7241-000.07). The combined footprint of the proposed dwellings is 1131m², compared to 1009m² in the Extant Approval (a 12% increase).
• 4.5 IMSP (§7.34.1) 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.

• 4.6 While older, street-facing built environment along the A3 is predominantly two storeys, with the adjacent hotel being three storeys, consideration has been given to the singlestorey developments on Carrick Park and Ballamanagh Close. The proposed houses are all bungalows, arranged in terrace, semi-detached, or detached configurations, with 35-degree pitched roofs and ridge lines typically 6.5m above ground floor level.
• 4.7 IMSP (§5.29) Spatial Policy 4:—

In the remaining villages development should maintain the existing settlement character and should be of an appropriate scale to meet local needs for housing and limited employment opportunities.

• 4.8 The Site is some 3½ miles from Ramsey’s centre, categorised in IMSP (§4.4.1) as the closest Major Employment Area. The existing bus stop will be upgraded to promote the use of this short, 10 to 15-minute journey (refer to §11 of this Statement).

• 4.9 The houses adopt a predominantly traditional style, with front elevations incorporating recessed elements to further break up their already modest forms. Horizontal cladding serves as a distinguishing yet cohesive feature throughout, complemented by darkcoloured window frames, rainwater goods, and roof finishes.
• 4.10 A low-maintenance approach has informed material selection. External elevations will feature white-painted render where not otherwise clad. Window frames, fascias and rainwater goods, will be uPVC. Photovoltaics will be flush with fibre cement roof tiles.

• 5.0 HOUSING MIX

• 5.1 IMSP (§8.4.9) Housing Policy 1:—

The housing needs of the Island will be met by making provision for sufficient development opportunities to enable 5,100 additional dwellings (net of demolitions), and including those created by conversion, to be built over the Plan period 2011 to 2026.

• 5.2 The Proposal includes the following house types, floor areas and POS quotas:—

Plot Detached Loft Bedrooms Garage NIA (m2) POS (m2)

• 01 ............. û ............ ü ................ 2 ................... û ................ 88.2 ............. 64
• 02 ............. û ............ û ................ 2 ................... û ................ 63.1 ............. 64
• 03 ............. û ............ û ................ 2 ................... û ................ 88.2 ............. 64
• 04 ............. û ............ û ................ 2 ................... û ................ 63.7 ............. 64
• 05 ............. û ............ ü ................ 2 ................... û ................ 88.2 ............. 64
• 06 ............. û ............ ü ................ 3 ................... ü .............. 118.0 ............. 96
• 07 ............. ü ............ ü ................ 4 ................... ü .............. 143.1 ............. 96
• 08 ............. ü ............ û ................ 2 ................... û ................ 68.9 ............. 64
• 09 ............. ü ............ û ................ 2 ................... û ................ 68.9 ............. 64
• 10 ............. û ............ û ................ 2 ................... û ................ 63.1 ............. 64
• 11 ............. û ............ û ................ 2 ................... û ................ 63.1 ............. 64
• 12 ............. û ............ û ................ 2 ................... û ................ 63.1 ............. 64
• 13 ............. û ............ û ................ 2 ................... û ................ 63.7 ............. 64
• 14 ............. û ............ û ................ 2 ................... û ................ 88.2 ............. 64

• 5.3 IMSP (§8.6.3) Housing Policy 5:—

In granting planning permission on land zoned for residential development or in predominantly residential areas [DEFA] will normally require that 25% of provision should be made up of affordable housing. This policy will apply to developments of 8 dwellings or more.

• 5.4 Policy requires in this instance that 3.5 dwellings be made available for IOMGov shared equity purchase assistance (First Time Buyers). Initial discussions with the Public Estates and Housing Division of the DoI have identified plots 11, 12, and 13 as the most suitable. A commuted sum would address the half-unit deficit.
• 5.5 The proposed dwellings have all been designed to exceed the requirements of the IOM Affordable Housing Standards Design Guide (2016), whether proposed for the open market or for IOMGov shared equity purchase assistance.

• 6.0 PUBLIC OPEN SPACE AND LOCAL AREA FOR PLAY

• 6.1 IMSP (§10.3.8) Recreation Policy 3:—

Where appropriate, new development should include the provision of landscaped amenity areas as an integral part of the design. New residential development of ten or more dwellings must make provision for recreational and amenity space in accordance with the standards specified in Appendix 6 to the Plan.

• 6.2 IMSP Appendix 6 stipulates that public open space should be allocated as approximately 56% formal open space, 19% children’s play space, and 25% amenity space. It is recognised that Sulby is a rural settlement, already benefiting from ample open space at the Claddagh nearby. As such, the Proposal has been designed with a greater emphasis on amenity space and suitable children’s play space.
• 6.3 IMSP (§A.6.4.2) requires 960m² of POS for this Proposal. This will be exceeded:—

Ref. Location Area (m2)

• A To the rear of the bus stop ......................................................................................... 122
• B Road verge north of plot 09 ......................................................................................... 18
• C Road verge north of plot 10 ......................................................................................... 23
• D Road verge north of plot 07 ......................................................................................... 12
• E Road verge between plots 06 and 07 ........................................................................... 14
• F Road verge north of plot 08 ......................................................................................... 32
• G Soft landscaping southeast of plot 08 ......................................................................... 216
• H Soft landscaping east of plot 14 (excluding LAP) .......................................................... 312
• I Local Area for Play (LAP) ............................................................................................ 233
• J Pedestrian access to LAP and Yn Claddagh ................................................................... 39
• K Soft landscaping and screening to rear of plots 09 and 13 ............................................. 56
• L Pedestrian access to rear plots 09 to 14 ........................................................................ 96

TOTAL ...................................................................................................................... 1,173

• 6.4 Where policy requires POS provision, this is typically conveyed to the local authority. If the local authority declines, the developer may enter into a covenant with DEFA and DoI to ensure the POS is maintained, managed, and kept in a neat and tidy condition.
• 6.5 Several road verges are proposed, incorporating either new tree planting or, if accommodating service routes, sown wildflowers. All street lighting will be positioned within road verge parcels that include service margins, rather than private curtilage.
• 6.6 A Local Area for Play (LAP) will include an activity zone of at least 200m², situated over 8m from the nearest dwellings. All proposed dwellings will be within 100m of the LAP.
• 6.7 The LAP will be fenced and gated, featuring a grassed lawn. The following equipment is proposed:—

Equipment Drawing

• • double cradle swings ................................................................................. 7241-000.20
• • play tower ................................................................................................. 7241-000.21
• • climbing frame .......................................................................................... 7241-000.22
• • two picnic benches .................................................................................... 7241-000.23

• 6.8 A footpath connecting the Proposal’s internal access road to Yn Claddagh will enhance pedestrian permeability, offering a more direct route to the Claddagh common land, which is frequently used by recreational walkers. The footpath will be illuminated during winter months by low-level bollard lighting. Barriers and road signage at the footpath’s junction with Yn Claddagh will help ensure pedestrian safety.

• 7.0 ECOLOGY AND LANDSCAPING

• 7.1 IMSP (§6.2) General Policy 2:—

Development which is in accordance with the land-use zoning […] will normally be permitted, provided that the development […] (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;[…]

• 7.2 The Act §2(2AA):—

The development plan must also take into account the following climate change policies established under the Climate Change Act 2021 — […] (c) the maintenance and restoration of ecosystems; (d) biodiversity net gain;[…]

• 7.3 The Proposal aligns with the Extant Approval and includes similar ecological provisions to enhance the Site’s biodiversity upon completion.
• 7.4 Where feasible and without interfering with service margins or drainage routes, hedges of various species will be incorporated instead of, or in addition to, timber fencing:—

Ref. Location Qty

• A Hawthorn (Crataegus monogyna) and Honeysuckle (Lonicera periclymenum) ............ 22 & 5
• B Hazel (Corylus avellana) and Honeysuckle (Lonicera periclymenum) ......................... 7 & 2
• C Hazel (Corylus avellana) and Honeysuckle (Lonicera periclymenum) ......................... 4 & 2
• D Hawthorn (Crataegus monogyna) .................................................................................. 44
• E Hazel (Corylus avellana) and Honeysuckle (Lonicera periclymenum) ....................... 28 & 6
• F Hawthorn (Crataegus monogyna) .................................................................................. 11
• G Blackthorn (Prunus spinosa) and Honeysuckle (Lonicera periclymenum) .................. 20 & 5
• H Hawthorn (Crataegus monogyna) .................................................................................. 15
• I Hazel (Corylus avellana) and Honeysuckle (Lonicera periclymenum) ......................... 8 & 3

TOTAL ......................................................................................................................... 182

• 7.5 The Extant Approval did not require POS provision but included 127m² of wildflowers, partly within private curtilages. In contrast, the Proposal allocates 177m² of wildflowers, all within POS areas, ensuring no reliance upon individual owners or occupiers.
• 7.6 The proposed site plan includes three wildflower seed mix recipes, each tailored to the expected sunlight conditions of respective POS areas following implementation.
• 7.7 The dwellings’ elevations will accommodate bird and bat boxes. A schedule of the boxes, detailing their locations, height, and orientation, is shown on the proposed site plan and the drawings showing the dwellings’ respective elevations. These aspects generally match those found in the Extant Approval.

• 8.0 ARBORICULTURAL IMPACT

• 8.1 The Act §2(2AA):—

The development plan must also take into account the following climate change policies established under the Climate Change Act 2021 (a) the maximisation of carbon sequestration;[…] (d) biodiversity net gain;[…]

• 8.2 IMSP (§6.2) General Policy 2:—

Development which is in accordance with the land-use zoning […] will normally be permitted, provided that the development […] (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks;[…]

• 8.3 An Arboricultural Impact Assessment by Manx Roots Limited examines the relationship between existing trees and the Proposal, the Extant Approval, and the 2018 approval. While the proposed dwellings will encroach upon some root protection areas, these incursions will be considerably less than those permitted under the Extant Approval.
• 8.4 An earlier version of the Proposal included an integral garage for Plot 10, which was later removed on the arboricultural consultant’s recommendation. This adjustment enabled the repositioning of Plots 11–14 further from Tree 6689. For comparison, Plot 2 of the Extant Approval was situated closer to this tree (drawing 7241-000.07).
• 8.5 Dutch Elm disease necessitates the removal of tree 1828, regardless of the Proposal. To mitigate this unavoidable loss, replacement tree planting is planned for the Site’s southern corner to re-establish a suitable level of screening to this side.
• 8.6 Fourteen trees of various species are proposed across the Site:—

Ref. Location Species

• A Plot 09 (front) ......................................................................... Silver birch (Betula pendula)
• B POS C ............................................................... Field maple (Acer campestre ‘Streetwise’)
• C POS C ............................................................... Field maple (Acer campestre ‘Streetwise’)
• D POS E ................................................................................... Sweet cherry (Prunus avium)
• E POS K .................................................................................. Sweet cherry (Prunus avium)
• F POS K ..................................................................................... Rowan (Sorbus aucuparia)
• G Plot 14 (rear) ................................................................... Common Pear (Pyrus communis)
• H Plot 07 (rear) ................................................................... Common Pear (Pyrus communis)
• I Plot 08 (rear) ....................................................................... Crab apple (Malus sylvestris)
• J POS G .................................................................................. Silver birch (Betula pendula)
• K POS G ................................................................................. Irish Oak (Quercus petraea)
• L POS G .................................................................................. Silver birch (Betula pendula)
• M POS G .................................................................................. Silver birch (Betula pendula)
• N POS G .................................................................................. Silver birch (Betula pendula)

• 8.7 No trees are proposed in conflict with service margins, the proposed drainage design or the existing public foul sewer which crosses the site.

• 9.0 DRAINAGE AND FLOOD RISK

• 9.1 IMSP (§7.12.5) Environment Policy 13:—

Development which would result in an unacceptable risk from flooding, either on or off-site, will not be permitted.

• 9.2 The Extant Approval was deemed acceptable, following consultation with the relevant authority, based on the raised site levels initially approved in 2018. The Proposal adopts similar ground floor levels to those in the Extant Approval, mitigating any potential surface water and river flood risks identified on indicative flood risk maps.
• 9.3 Drainage calculations have been prepared by Burroughs Stewart Associates Limited (also appointed during the Extant Approval). These assess the Site’s percolation, the Proposal’s drainage area, and calculate the required stormwater attenuation.
• 9.4 The Proposal’s increased impermeable area will require greater attenuation capacity. As the access road is expected to be adopted, the updated drainage design relocates attenuation from beneath the road to POA area “A.” There may also be an opportunity to incorporate some attenuation beneath certain driveways.
• 9.5 During the Extant Approval, it was anticipated that the currently undersized culvert crossing the A3 highway would require upgrading. The drainage calculations for the current Proposal specify a replacement culvert, designed in accordance with CIRIA C786. This was previously accepted by PABC as a detailed matter controlled under separate legislation (the Flood Risk Management Act 2013).
• 9.6 An existing road gulley, currently located at the proposed bell-mouth junction, will be replaced by two gulleys beside the entrance ramp. The other ramp, south of Plot 10, will also be drained at its low side.
• 9.7 The drainage plan illustrates the proposed foul and surface water drainage connection routes for each plot, as well as the proposed sewer routes.

• 10.0 ENERGY CONSERVATION

• 10.1 The Act §2(2AA):—

The development plan must also take into account the following climate change policies established under the Climate Change Act 2021 —

• (a) the maximisation of carbon sequestration;[…]
• (b) the minimising of greenhouse gas emissions;[…] and (f) the provision of active travel infrastructure.

• 10.2 IMSP (§6.2) General Policy 2:—

Development which is in accordance with the land-use zoning […] will normally be permitted, provided that the development […] (n) is designed having due regard to best practice in reducing energy consumption.;[…]

• 10.3 IMSP (§12.2.11) Energy Policy 5:—

[DEFA] will prepare a Planning Policy Statement on Energy Efficiency. Pending the preparation and adoption of that PPS [DEFA] will require proposals for more than 5 dwellings or 100 square metres of other development to be accompanied be an Energy Impact Assessment.

• 10.4 The Building Control (Approved Documents) (Amendment) Order 2019 currently requires dwellings to achieve a Standard Assessment Procedure (SAP) value of 93, which the Proposal will meet through a fabric-first approach.
• 10.5 The wall widths shown in the proposed floor plans are designed to accommodate the thermal insulation thicknesses required to achieve the lowest necessary thermal transmittance (U-value).
• 10.6 It is anticipated that the dwellings will be of traditional cavity-wall construction. The internal leaf of masonry will contribute to the dwelling’s thermal mass, helping to mitigate diurnal fluctuations. External, sustainably sourced cladding will help reduce the extent of painted cement render required.
• 10.7 The more compact a building is, the easier it is to meet energy-efficiency standards. The majority of the proposed dwellings will have a terraced or semi-detached form, reducing the surface area-to-volume ratio and thereby minimising heat loss.
• 10.8 The dwellings will be designed with sealed junctions and lapped membranes to achieve an air-tightness of 5.0m³/h·m² or better. The exact target air permeability level will be calculated before submitting Building Control applications.
• 10.9 The number of apertures in the external envelope has been minimised to simplify construction and reduce the likelihood of leakage. Habitable spaces will still receive sufficient daylight for their intended purpose, however, without undue reliance on artificial lighting. Apertures within recessed elements of front elevations will permit greater daylight admittance to the deeper parts of habitable spaces.
• 10.10 All external light fittings will be energy efficiency rated, including street light columns and bollards. Security lighting will be controlled by PIR sensors and automatic timers.
• 10.11 Where fixed appliances are to be provided (including ovens, hobs, extractor hoods, microwave ovens, fridges, freezers, washing machines, dryers, and dishwashers), these will be supplied with an energy efficiency label rating. Purchasers will also be advised on the specification of energy-efficient appliances.
• 10.12 Each dwelling will be equipped with photovoltaic panels, optimally oriented to align with the Site’s solar path while considering any shadows cast by the surroundings. Given their modest size, the dwellings are not anticipated to require air source heat pumps. Appropriately routed ducts may be provided during construction, however, to allow for future installation if desired by purchasers.
• 10.13 None of the dwellings will include an oil or gas-fired boiler for space or water heating. Instead, they will utilise an electric boiler and Manx Utilities’ Comfy Heat tariff.
• 10.14 Fixtures in each dwelling will be specified to reduce water consumption, including pressurised or reduced-flow showers, dual-flush toilets, and energy-efficient washing machines and dishwashers.

• 11.0 HIGHWAYS, ACCESS AND PARKING

• 11.1 IMSP (§6.2) General Policy 2:—

Development which is in accordance with the land-use zoning […] will normally be permitted, provided that the development […] (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space;[…] (i) does not have an unacceptable effect on road safety or traffic flows on the local highways;[…]

• 11.2 IMSP (§11.3.1) 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.

• 11.3 Due to the extent of changes since the Extant Approval, HSDC has confirmed the requirement for a new Stage 1 Road Safety Audit. This has been prepared by Highway Mann Traffic Consultants Limited and assessed a previous iteration of the Proposal, resulting in several refinements, which are documented in the designer’s responses. A swept path analysis for a refuse vehicle has also been prepared to demonstrate adequate manoeuvring space for the largest anticipated vehicle.
• 11.4 MfMR (Table 6.9) prohibits private roads from serving more than five dwellings. The proposed road has therefore been developed to the standards prescribed in MfMR (Table 6.7) for a Shared Surface Street.
• 11.5 The Proposal is accessed by a single road from a new junction onto the A3 highway. A bus shelter is proposed to upgrade a signed bus stop. Both the bus shelter’s location and the new junction’s geometry are identical to those shown in the Extant Approval.
• 11.6 IMSP (§11.5.3) Transport Policy 7:—

[DEFA] will require that in all new development, parking provision must be in accordance with [DEFA]’s current standards.

• 11.7 IMSP Appendix 7 sets out the parking requirements for residences. Typical residences require two spaces, one within the curtilage and behind the front of the dwelling. Terraced dwellings also require two spaces, which, if not within the curtilage, should be as close as possible. Each of the dwellings is provided with two parking spaces.
• 11.8 Whereas some developments have previously provided allocated parking spaces for terraced dwellings together in a communal car park, the Proposal locates at least one parking space adjacent to each respective dwelling. This arrangement permits each dwelling to install charging equipment for electric vehicles, if required.
• 11.9 MfMR (§C.2.10) :—

Where garages are not provided for single dwellings, a shed may be provided in lieu of this. For 1-2 bedroom properties, these must be a minimum of 2400 mm by 1800 mm.[…]

• 11.10 The dwellings at plots 06 and 07 will each have an integral single garage. The remaining plots, each with a maximum of two bedrooms, will be provided with a 2.4m by 1.8m shed (as shown on the proposed site plan and drawing 7241-000.24) within their curtilage. Plots 01 and 05 previously featured an integral garage, however these were omitted in amended plans at HSDC’s request; garages are not necessarily a convenient means of parking and may instead be used as storage, increasing the chance of on-street parking.
• 11.11 POS area “L” will provide a minimum 1.6m wide rear garden access to plots 09 to 14, facilitating the movement of cycles or other equipment, and entirely eliminating the need for cycles to traverse inside of dwellings.
• 11.12 IMSP (§4.5.1) Strategic Policy 10:—

New development should be located and designed such as to promote a more integrated transport network with the aim to:

• (a) minimise journeys, especially by private car;
• (b) make best use of public transport;
• (c) not adversely affect highway safety for all users, and
• (d) encourage pedestrian movement.

• 11.13 The Extant Approval included the upgrade of the current bus stop to a bus shelter with Kassel-type kerbing to facilitate commuter access. The Proposal maintains this provision. The increased number of dwellings is expected to further encourage the use of public transport. An overhead electricity supply will be ducted underground at the request of the relevant authority. This will, in turn, permit the proposed bus stop to be sited farther from the proposed access junction than shown in the Extant Approval.
• 11.14 The lane adjacent to the Local Area for Play will facilitate pedestrian movement through the Site (see §6.8 of this Statement).

• 12.0 SUMMARY AND CONCLUSIONS
• 12.1 The provision of affordable homes addresses a critical shortfall in supply, which represents a key material consideration in the Application’s favour. Specific plots have been identified for shared equity purchase assistance, while a commuted sum will mitigate the half-unit shortfall. The Local Area for Play, equipped with various play structures, will serve the young families that these homes will likely accommodate. An accessible pedestrian route will improve connectivity and pedestrian safety.
• 12.2 The Proposal aligns with biodiversity objectives by incorporating several ecological enhancements, including various hedges to replace or supplement timber fencing, increasing wildlife support. Bird and bat boxes will be integrated into the dwellings’ elevations, further enhancing ecological value. The Extant Approval is improved upon by expanding wildflower areas within Public Open Spaces, to ensure long-term maintenance, demonstrating a commitment to sustainability and biodiversity gain.
• 12.3 Tree root incursions are minimised compared to previous approvals, with adjustments having been made to protect key trees. One diseased tree will require removal in any event, but mitigation measures include planting 14 new trees of various species across the site. Planted trees will contribute to screening and landscape integration but will not interfere with drainage, service margins, or existing infrastructure.
• 12.4 The drainage plan details foul and surface water sewers and individual connections throughout. The proposal maintains ground floor levels consistent with those of the Extant Approval. Updated drainage calculations account for an increase in impermeable areas, relocating stormwater attenuation to Public Open Space. A previously undersized culvert will be upgraded under separate statutory provisions.
• 12.5 The proposed dwellings feature modest, traditional, yet innovative designs that harmonise with, and are sympathetic to, the surrounding diverse built environment. These adopts a fabric-first approach, prioritising insulation and airtight construction to minimise heat loss. The dwellings’ compact designs will enhance energy efficiency, while photovoltaic panels will be installed on all homes. Water-efficient fixtures and energy-rated appliances will further reduce resource consumption.
• 12.6 The Proposal incorporates provisions for future installation of air source heat pumps and EV chargers. Each dwelling will include two parking spaces. Terraced plots without garages will have sheds for cycle storage, accessed via a dedicated rear lane.
• 12.7 The Proposal ensures safe, efficient access for all users by adhering to IMSP transport policies and MfMR standards. A new Stage 1 Road Safety Audit has informed design refinements, and a swept-path analysis confirms adequate space for service vehicles. The Proposal upgrades a signed bus stop to a shelter, promoting public transport use.
• 12.8 The Proposal has been shaped by thorough assessment of the Site’s constraints to optimise development potential. This will deliver greater benefits than the comparable Extant Approval (which remains capable of implementation). A modest 12%-increase in built footprint is justified, as all applicable policy requirements continue to be met.