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21/00527/B Page 1 of 9
PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 21/00527/B Applicant : Douglas Borough Council Proposal : Creation of a controlled parking area for motorhomes Site Address : The "Boneyard" Hard Standing Area To Rear Of Grandstand And Adjacent To Bowling Green Noble's Park Douglas IM2 6DA
Principal Planner: Mr Chris Balmer Photo Taken : Site Visit :
Expected Decision Level : Planning Committee
Recommendation
Recommended Decision:
Permitted Date of Recommendation: 15.07.2021 __
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 use hereby approved is only for the use of the site as a motorhome "aire" as set out in the approved documents, and the site may only be operated by Douglas Borough Council.
Reason: The applicants (DBC) have clearly outlined without their submission how the site will be run and operated and the application has been considered on this basis's only.
C 3. For the avoidance of doubt no tents or awnings may be erected or used on the site outside of TT/Racing periods.
Reason: The application has not proposed tents or awnings (submitted statement indicates they would not be used) and the application has been considered on this basis.
C 4. There may be no more than 75 motorhomes parked at the site at any one time (outside TT/Racing periods).
Reason: there are 75 spaces available within the site and the application has been considered on this basis and in the interest of the visual amenities of the area.
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C 5. A motorhome shall only be allowed to park on the site for a maximum of 4 nights (outside TT/Racing periods).
Reason: The application has been proposed and judged on the parking of motorhomes on a short terms basis for tourist/visitor use only.
C 6. No operation of the site hereby approved shall take place until full details of soft landscaping works have been submitted to and approved in writing by the Department and these works shall be carried out as approved. Details of the soft landscaping works include details of new bushes/hedgerows/tree planting showing, type, size and position of each especially along the northern and eastern boundary of the site. All planting, seeding or turfing comprised in the approved details of landscaping must be carried out in the first planting and seeding seasons following the occupation of the site. Any trees or plants which die or become seriously damaged or diseased must be replaced in the next planting season with others of a similar size and species.
Reason: To ensure the provision of an appropriate landscape setting to the development.
This application has been recommended for approval for the following reason. It is considered the additional use of the site for a motorhome "aire" proposal would result in an additional recreation facility for IOM residents and visitors and would use a site which is used and has facilities which serve this very purposes during the TT /racing periods. The proposal also has no significant impacts upon public or private amenities. Accordingly it is considered the proposal would comply with General Policy 2, Environment Policy 22, Environment Policy 24 & Recreation Policy 2 of the IOM Strategic Plan 2016 and the Area Plan for the East 2020.
Plans/Drawings/Information;
This approval relates to the submitted documents and drawings all received on 19.05.2021. __
Interested Person Status - Additional Persons
It is recommended that the following persons should not be given Interested Person Status as they are not considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
The owner/occupier of Scarlett, Tennis Road, Douglas as they do not clearly identify the land which is owned or occupied which is considered to be impacted on by the proposed development in accordance with paragraph 2A of the Policy; are not within 20m of the application site and the development is not automatically required to be the subject of an EIA by Appendix 5 of the Strategic Plan, in accordance with paragraph 2B of the Policy; as they do not refer to the relevant issues in accordance with paragraph 2C of the Policy and as they have not explained how the development would impact the lawful use of land __
Officer’s Report
THIS APPLICATION IS REFERRED TO THE PLANNING COMMITTEE BECAUSE THE PROPOSAL COULD BE CONSIDERED CONTRARY TO THE DEVELOPMENT PLAN BUT RECOMMENDED FOR AN APPROVAL
1.0 THE APPLICATION SITE
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1.1 The application site forms part of The "Boneyard", which is an area of land which is made up of tarmac/stone access lanes with grassed areas in-between. The site is to the south of the Grandstand/Paddock and east of the Bowling Green within Noble’s Park, Douglas.
2.0 THE PROPOSAL 2.1 The application seeks approval for the creation of a controlled parking area for motorhomes outside TT periods. The applicants comment:
"The aim of the strategy is to improve the management and enforcement of vehicle parking in Noble's Park to eliminate the use of the park for the storage and parking of inappropriate vehicles and to minimise vehicle movements in areas of the park with high amenity value and higher levels of pedestrians. The strategy also aims to improve routes through the park for pedestrians, runners and cyclists as it is considered to be able to offer an important contribution to an active travel network in this part of Douglas.
This application is for the additional use of the paddock area, currently designated for TT use, as car parking outside TT and other motorsport periods. This is an existing use and this application aims to formalise the use so that it can be effectively managed through the making of an Off-street Parking Places Order. The Order has been drafted with the assistance of the Department of Infrastructure and the Council intends to make the Order once planning consent has been received. The Department has also drafted Traffic Regulation Orders for the roadways within the park with the intention that these be made once planning consent is in place."
2.2 Further the applicant's state:
"The "Boneyard" area of Noble's Park is situated with the BMX track and dog walking area to the southeast and the TT shower block to the north west. The area is zoned in the Area Plan for the East as Open Space - Park. During the periods when the park is occupied for motorsport events the "Boneyard" is used for the parking of motorhomes and camping by competitors and their teams. An infrastructure of electricity supply points has been installed over the years to support this use during motorsport events. There is also a shower and toilet block located adjacently for use by those camping during the festivals.
Outside the motorsport festival periods, the area cannot easily be used for any other purpose because of the infrastructure required during the festival periods. For many years the Council has issued permits to motorhome users permitting them to park motorhomes under certain conditions including a maximum stay of 4 consecutive nights or 14 days in any quarter. However, until the making of the Noble's Park Off-Street Parking Places Order 2021 in January 2021, the Council had no enforcement powers available. Since the making of the Order, the Council is now enforcing a prohibition of motorhome parking in Noble's Park as a measure to tackle the problem of motorhome owners storing their vehicles permanently within the park."
2.3 Additional comments are: "It was also recognised that the provision of official motorhome overnight parking has some potential benefits. Most motorhomes are completely self-contained and consequently their users are not physically constrained by the need for the facilities provided by full campsites. As a result motorhomes are able to be used anywhere they are permitted and this is part of their attraction. The only facilities required are a flat location to park and the occasional need to empty a chemical toilet and 'grey' water and to top up the tanks with fresh water. An electricity supply, toilets and showers, although not required are considered a bonus. Many towns, particularly in mainland Europe provide facilities called Aires or Stellplatz of just this nature where motorhomes are invited to park either free of charge or for a tariff typically much lower than a fully equipped campsite. The main differences between a Stellplatz and a campsite are; o Users can arrive or depart at any time, even at night. o There is no reception where one has to register or deregister.
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o Sanitary facilities are not available, or at least only to a limited extent. o The erection of tents, including awnings, is not permitted. o The stay is limited to a few nights, seasonal or permanent camping is not permitted. o Lower accommodation prices, sometimes free of charge. o In the case of chargeable spaces, the fee is usually paid at a parking ticket machine or an honesty box.
The town authorities provide the Aires/Stellplatz in recognition that motorhome owners will spend money in the local economy and that although they are not paying for accommodation, they will buy food, supplies, fuel and visit local bars and restaurants. Furthermore, the "Boneyard" area is located adjacent to the newly refurbished BMX track and offers the potential for BMX riders and their families to visit in motorhomes and stay right next to the facility.
The Visit Isle of Man website lists fourteen campsites suitable for motorhomes. None of these are located in Douglas, the nearest being Glen Dhoo Campsite and Lower Ballacottier Campsite both in Onchan. Glen Dhoo Campsite is over three miles from the centre of Douglas and is only open during the motorcycling festivals and Lower Ballacottier Campsite is four miles from the centre of Douglas and a twenty to thirty minute walk from the nearest bus stop. Neither of these campsites are suitable for tourists or other Manx motorhome owners wishing to stay within walking distance of the centre if visiting Douglas's pubs, bars or restaurants.
Motorhomes are generally over 5 metres in length and considerably higher than normal vehicles. As a consequence they do not fit in multistorey car parks and cannot be parked in standard 4.8 metre long parking bays. All off-street car parks in Douglas town centre have marked bays and so it is an offence for motorhomes to use them if they overhang the bay. Consequently the only place for visiting motorhomes to park is on street. The provision of the aire in Noble's Park would provide a suitable location for visiting motorhomes to be parked whilst their occupants are visiting the shops and services in Douglas town centre. The Visit Isle of Man website actively encourages people to bring their motorhomes to the island and it is reasonable to expect visiting motorhomers to want to visit the Manx Museum, shops, the Steam railway and the electric railway but currently there are no off-street parking places for them to park their vehicles in the capital. Noble's park is a 15 minute walk from the Promenade and is within very easy cycling distance which will be improved further once the proposed active travel infrastructure is delivered."
2.4 Further comments can be found within the applicants Planning Statement.
3.0 PLANNING HISTORY 3.1 Parts of Nobles Park have various approvals for temporary uses associated with TT and the Festival of Motorcycling. However the following are considered relevant in the determination of this application:
Application site 3.2 Creation of paddock roads - 10/00250/B - APPROVED. This application proposed the creation of roadways within the application site, but also the land to the east of this site (not included in currently application site). The aim was to provide formal access ways and avoid the damage and visual impact which resulted from heavy use in periods of inclement weather. The proposal was to formalise tracks which have been formed through use over time.
3.3 Creation of an open air storage compound - 07/01993/B - REFUSED on the following grounds: "R 1. The proposed open air storage compound would be contrary to the Douglas Local Plan 1998 in that insufficient justification has been submitted to support the introduction of a storage compound into an area of Public Open Space.
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R 2. The open air storage compound by reason of its siting, height and design would introduce a prominent and incongruous feature into an area of open space which will impact on the overall setting of the park to the detriment of the visual amenities of the locality."
3.4 Approval in principle for the creation of a six court tennis centre and facilities - 99/01795/A - APPROVED
3.5 Approval in principle for creation of an indoor karting track and facilities - 99/01794/A - APPROVED
3.6 Construction of new bowling centre & associated leisure facilities - 92/00574/B - APPROVED
3.7 Construction of leisure complex, tennis court area - 90/01453/B - APPROVED
3.8 Approval in principle for construction of bowling centre, upper tennis courts - 90/00028/A - APPROVED
Paddock Car Park 3.9 Change of use of part of existing car park for the parking of Heavy Goods Vehicles, Motor Homes and other large vehicles - Paddock Car Park, Nobles Park, Douglas - 11/01741/C refused on the following grounds:
"R 1. The proposed use of land for the parking of Heavy Goods Vehicles, Motorhomes and other large vehicles would be contrary to Recreation Policy 2 and Environment Policy 42 of the Strategic Plan since it would result in a loss of space for recreation purposes or which has the ability to be used for recreation purposes.
R 2. The proposed use would have an unduly detrimental impact upon the character of the area and be harmful to visual amenity contrary to Strategic Policy 5 and Environment Policy 42."
4.0 PLANNING POLICY 4.1 The site is designated as "Public Open Space - Park" under the Area Plan for the East 2020. The site is not within a Conservation Area.
4.2 The following policies in the Isle of Man Strategic Plan 2016 are considered relevant:
4.3 General Policy 2 states: "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: (a) is in accordance with the design brief in the Area Plan where there is such a brief; (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; (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses; (e) does not affect adversely public views of the sea; (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks; (g) does not affect adversely the amenity of local residents or the character of the locality; (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;
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(j) can be provided with all necessary services; (k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan; (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding; (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and (n) is designed having due regard to best practice in reducing energy consumption."
4.4 Environment Policy 22 states: "Development will not be permitted where it would unacceptably harm the environment and/or the amenity of nearby properties in terms of: i) pollution of sea, surface water or groundwater; ii) emissions of airborne pollutants; and iii) vibration, odour, noise or light pollution."
4.5 Environment Policy 24 states: "Development which is likely to have a significant effect on the environment will be required: i) to be accompanied by an Environmental Impact Assessment in certain cases; and ii) to be accompanied by suitable supporting environmental information in all other cases."
4.6 Recreation Policy 2 states: "Development which would adversely affect, or result in the loss of Open Space or a recreation facility that is or has the potential to be, of recreational or amenity value to the community will not be permitted except in the following circumstances: (a) where alternative provision of equivalent community benefit and of equivalent or better accessibility is made available; and (b) where there would be an overall community gain from the development, and the particular loss of the open space or recreation facility would have no significant unacceptable effect on local open space or recreation provision or on the character or amenity of the area."
5.0 REPRESENTATIONS 5.1 Douglas Borough Council raises no objection (25.05.2021).
5.2 DOI Highway Services comment (04.06.2021); "After reviewing this Application, Highway Services find it to have no significant negative impact upon highway safety, network efficiency and /or parking".
5.3 The owner/occupier of Scarlett, Tennis Road, Douglas objects to the application which can be summarised as (11.06.2021); Regardless of site's usage history this site has wonderful sea/town views, for ease of public access is the best anywhere, has been sorely neglected and deserves the same Corporation attention lavished on Douglas Head; are should be improved with sheltered areas, raised viewing veranda and more amenities such as more table tennis tables; Rentable garden allotments would be more appealing than parked motorhomes; Keep our park unspoilt for pleasure for all people; The Bone Yard is the wrong place for such a messy business. Motorhomes become dirty. Also they may become neglected, broken down, abandoned and for multiple reasons used legally or illegally.
6.0 ASSESSMENT 6.1 It is considered that the main issues are: principle of development; the potential impact upon neighbouring residential amenities; potential impact upon visual amenities of the area; potential impacts of noise/air pollution; and access and parking.
Principle of development 6.2 The area is used as a paddock during race periods. Further, no physically works are proposed by this development. The applicants are only seeking the additional use of this area for the purposes of controlled parking area for motorhomes outside TT periods.
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6.3 Given the site is required during the TT periods, and the electrical poles and hardstanding and access roads are required to be in place throughout the year; what results is this site use; throughout the remaining of the year, is quiet limited. For example the site couldn't be used as a play area or football field etc., given the existing infrastructure which exists for the TT requirements. The applicants are seeking to introduce "Aires/Stellplatz" style facilities (as outlined in their statement) where people are able to park their motor homes on the site for a limited period and be able to use the park facilities or visit Douglas. As outlined there are no campsites (this wouldn't be a campsite i.e. tents etc.) or similar accommodation within Douglas and this would introduce should facility.
6.4 The test from a land use point of view is whether the development would adversely affect, or result in the loss of Open Space or a recreation facility that is or has the potential to be, of recreational or amenity value to the community. If it does then it is required to (a) where alternative provision of equivalent community benefit and of equivalent or better accessibility is made available; and (b) where there would be an overall community gain from the development, and the particular loss of the open space or recreation facility would have no significant unacceptable effect on local open space or recreation provision or on the character or amenity of the area.
6.5 In this case given the existing use of the area for TT uses (for the parking of motor homes etc. associated with the TT Teams) it is difficult to argue that the site has a high amenity value to the community given the use and the requirements/facilities that has resulted on the site. The proposal to operate the site as a pay & display motorhome aire would alleviate the problem of vehicles being stored within Noble's Park but would retain the recreational/leisure facility within the park. Arguable, the proposal would provide a new recreation facility on this site which has an equivalent community benefit and therefore comply with Recreation Policy 2.
The potential impact upon neighbouring residential amenities 6.6 The site is located a distance away from neighbouring properties and therefore, the use of the motorhomes and perhaps people outside these are unlikely to cause a significant impact through noise. Further the amount of traffic generated by the development is unlikely to be substantial. The applicants undertook traffic monitoring, which was done at 3 points; the entrance opposite Police Headquarters, the main St Ninian's Road entrance and outside the Pavilion. The survey suggested that there were approximately 1,345 vehicle movements through the park each week (16,140 annually). The applicants anticipate that approximately if there are 50 vehicles and that each vehicle leaves and enters the park on four occasions each year, it equates to four hundred vehicle movements each year out of the 16,000 annual movements. Accordingly, it is not considered this additional level of traffic would have a significant impact, especially given there are two access to the site so this figure would be split.
The effect of the proposal upon the character and appearance of the area 6.7 The parking of the motorhomes will mainly be apparent when viewed from the surrounding areas within the park, namely the Paddock, dog walking area to the south. Public views outside the site would likely be limited to the east from the Dukes Road which pass the Police Headquarters. There is existing mature landscaping along half the eastern boundary of the site which will mitigate views of the motorhomes from these views. Further, there is the opportunity for additional landscaping along the eastern boundary of the site (or between the site & Dukes Road).
6.8 Overall, while the motorhomes would be apparent from distance public views (Dukes Road & immediately adjacent to the site within the park); given the existing use of the site; which consequently has the appearance as parking provision for motorhomes, it is not necessary considered to be out of place sufficiently to warrant a refusal. The parked motorhomes, will have a visual impact, given they are general white rectangles on wheels,
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however, given the existing landscaping and potential for additional landscaping, it is considered the visual impact can be adequately mitigated.
potential impacts of noise/air pollution 6.9 The applicant have produce an Environment Impact Assessment as per the requirements of Environment Policy 24 , albeit the site is not a campsite which generally requires a EIA, the applicants have accepted it is a similar use and therefore have included one. This considered a number of issues including noise and air pollution. The reports concludes:
"The motorhome aire proposal alone would have no discernible impact on traffic movements within the park however, the compound effects of the traffic management proposal to prohibit vehicles from exit the main car park onto St Ninian's Road and the enforcement power provided by the proposed Parking Places Order would be to reduce traffic movements. o The proposal would reduce the average number of motorhomes present in the park at any given time and eliminate unauthorised long term and unsightly storage of the vehicles. o The site is in an ideal location to encourage the use of active travel into Douglas town centre. o The proposal is unlikely to generate a level of noise that would cause disturbance in the surrounding area. o The proposal would allow the 'boneyard' area to contribute to the park's recreation and leisure amenity value throughout the year rather than just during the motorsport festival periods without impacting on their ability to be used during the festivals. o The proposal could prevent water pollution impacts elsewhere on the island by encouraging use of the facilities already available in the park for the disposal of effluent. o The proposal has the potential to reduce the landscape impact of motorhomes within the park."
6.10 Overall, the EIA conclusions and assessment raise no concerns; neither does the use of the site as a motorhome aire proposal.
Access and parking 6.11 Highway Services have considered the scheme and raise no objection.
7.0 CONCLUSION 7.1 Overall, it is considered the additional use of the site for a motorhome "aire" proposal would result in an additional recreation facility for IOM residents and visitors and would use a site which is used and has facilities which serve this very purposes during the TT /racing periods. The proposal also has no significant impacts upon public or private amenities. Accordingly it is considered the proposal would comply with General Policy 2, Environment Policy 22, Environment Policy 24 & Recreation Policy 2 of the IOM Strategic Plan 2016 and the Area Plan for the East 2020. The application is recommended for an approval.
8.0 INTERESTED PERSON STATUS 8.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons: (a) the applicant (including an agent acting on their behalf); (b) any Government Department that has made written representations that the Department considers material; (c) the Highways Division of the Department of Infrastructure; (d) Manx National Heritage where it has made written representations that the Department considers material; (e) Manx Utilities where it has made written representations that the Department considers material; (f) the local authority in whose district the land the subject of the application is situated; and (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material.
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8.2 The decision maker must determine: o whether any other comments from Government Departments (other than the Department of Infrastructure Highway Services Division) are material; and o whether there are other persons to those listed above who should be given Interested Person Status. __
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.
Decision Made : ...Permitted... Committee Meeting Date:...26.07.2021
Signed :...C BALMER... Presenting Officer
Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report).
Signatory to delete as appropriate YES/NO See below
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