11 October 2019 · Planning Committee
Sea Wall, Queens Promenade, Douglas, Isle Of Man, IM2 4nr
The Department of Infrastructure proposed constructing a 507m long reinforced concrete wall, 1.2m high above the promenade walkway, anchored to the existing sea wall from Loch Promenade to Central Promenade.
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The Planning Committee disagreed with the officer's recommendation for approval, refusing the application because the permanent and detrimental impact on the character and appearance of the Conservati…
Environment Policy 35
Requires development in Conservation Areas to preserve or enhance character and protect special features. Officer found design responds to historic context with pier replication and artwork, but Committee deemed permanent solid wall introduces unacceptable harm by replacing open railings, altering views.
Planning Policy Statement 1/01 - Policy CA/2 (Conservation Areas)
Sets standards for Conservation Areas. Applied to assess setting of historic features like Gaiety Theatre and Jubilee Clock; mitigations noted but Committee found detrimental impact on historic character not outweighed.
General Policy 2
Requires respect for scale/form/design, no adverse townscape impact, no loss of public sea views (e). Officer accepted minor view loss for some users mitigated by platforms; Committee found contrary to (e) due to impact on shorter users unable to see over 1.2m wall.
Environment Policy 11
Permits coastal works if not increasing/transferring flood risk or prejudicing natural defences. Flood assessment confirmed no increased risk elsewhere; supported by JBA models and valves.
Environment Policy 12
New coastal defences must not unacceptably impact coastal character/ecology/archaeology. EIA addressed with mitigations; officer found acceptable.
Strategic Policy 4
Proposals must protect or enhance Conservation Areas. Negative impact acknowledged but not refusal reason for officer.
No impacts from wall itself, but construction requires management plan (to be conditioned)
No objection raised, though disappointment wall not full length
Highways provided conditional no objection requiring a Construction Management Plan; Douglas Borough Council/Douglas Corporation ultimately raised no objection but expressed disappointment that the wall was not the full length of the Promenade.
Key concern: disappointment that the wall was not being constructed the full length of the Promenade
Department of Infrastructure Highways
Conditional No ObjectionThe proposed wall does not have any related highways impacts to the day to day movement of traffic along the promenade; therefore, the development is considered acceptable from a highway's aspect.; However, the construction of the promenade wall will require a construction management plan.; Recommendation: DNOC
Conditions requested: No works shall commence on site until a method of construction statement has been submitted to and approved in writing by the Local Planning Authority to include details of: i) the access and layout of on-site car parking for site personnel, operatives, and visitors ii) turning, loading, and unloading of vehicles, plant, and materials iii) storage of plant and materials iv) a programme of works, including routes for construction traffic, measures for traffic management v) hours of construction, including deliveries and construction vi) any proposed temporary traffic restrictions for pedestrians / cyclists and vehicles vii) the provision of any boundary hoardings behind any visibility zones. The approved details shall be implemented and adhered to throughout the construction period. Any variation shall be agreed in writing by the Local Planning Authority.
Douglas Corporation
No ObjectionFollowing consideration of the application the Council resolved that no objection be raised.; In reaching its determination, the Committee expressed, on behalf of the Council, disappointment that the wall was not being constructed the full length of the Promenade.
Original application 19/00755/B for 507m long 1.2m high reinforced concrete wall anchored to existing sea wall was refused by Planning Committee on 11/10/2019 despite officer recommendation for approval, citing permanent detrimental impact on Douglas Promenades Conservation Area character/appearance and public sea views (contrary to EP35, CA/2, GP2.e) not outweighed by flood risk benefits, noting lower protection than recommended and intermittent risk. Appellant (DOI) argued minimal heritage harm outweighed by flood protection needs, supported by EIA, Heritage Proof, JBA technical note showing improved SoP vs existing defences. Council defended refusal emphasising 'Fortress Prom' visual impact, unproven need, alternatives unexplored. Inspector found neutral CA impact overall, minor sea view conflict with GP2(e) outweighed by flood benefits, horse tram protection, public safety/economic gains; no better alternatives; recommended ALLOWED with conditions.
Precedent Value
Sets precedent that quantified flood risk reduction (even partial SoP) + public safety/economic benefits can outweigh minor CA/sea view harms in coastal defence schemes if design-sensitive and alternatives explored; future applicants must provide full EIA/heritage assessments upfront and demonstrate policy benefits explicitly outweigh harms.
Inspector: Brian J Sims BSc(Hons) CEng MICE MRTPI
