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PLANNING OFFICER REPORT AND RECOMMENDATION
Application No. : 22/00492/B Applicant : Department Of Infrastructure Proposal : Engineering works to existing bridge and provision of a new pedestrian footpath on the west side of the bridge Site Address : Santon Bridge Main Road Santon Isle Of Man IM4 1EN
Planning Officer: Mr Paul Visigah Photo Taken :
Site Visit : 18.08.2022 Expected Decision Level : Officer Delegation
Recommendation
Recommended Decision:
Refused Date of Recommendation: 03.10.2022 __
Reasons for Refusal
R : Reasons for Refusal O : Notes attached to reasons
R 1. The application is contrary to section 16 of the Town and Country Act 1999 as the special architectural and historic interest of the building's setting is not being preserved. The application is also judged to fail the tests of planning policy statement 1/01 as well as strategic policy 4 and Transport Policy 3 of the IOM Strategic Plan 2016, and Urban Environment Proposal 3 of the Area Plan for the East, as the setting of the registered building is not being protected or preserved, and traditional materials are not being used. The application is therefore judged to be unacceptable.
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Interested Person Status - Additional Persons
It is recommended that the following Government Departments should be given Interested Person Status on the basis that they have made written submissions relating to planning considerations:
Manx National Heritage __
Officer’s Report
1.0 THE SITE
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1.1 The site is the Santon Bridge which connects Min Road Santon and sits over the steam railway line which connects the east and to the south of the Island. The bridge lies northwest of the Santon Station, and forms part of the visual setting of the Santon Railway Station which is entered on the protected buildings register (Registered Building No. 278) as a building of special architectural or historic interest. The bridge can be viewed from the platform looking east towards the main Douglas to Castletown road.
1.2 The bridge which has significant vegetation and shrubbery on both sides is a Manx stone bridge 24m long and 7m wide (internal width). This bridge has a Manx stone wall 1m high and 500mm wide on both sides, with a pedestrian access point about 700mm wide on the eastern side.
1.3 Below the bridge is an arched passage which serves the heritage rail line. This forms a congruent unit with the large sections of Manx stone wall which serves as retaining walls on both sides of the bridge.
2.0 THE PROPOSAL 2.1 The proposal seeks planning approval for engineering works to existing bridge and provision of a new pedestrian footpath on the west side of the bridge.
2.2 The proposed works would involve the widening of the internal width of the existing bridge from 7m to 11m. The new bridge would be formed by reinforced concrete cantilever which would also form the new base of the road that would be 300mm thick. The new bridge would be 2.9m high from its base (1.5m above the road level), have a 765mm wide pedestrian area to the east, while a larger pedestrian footpath 2.6m wide would be created on the western side. The reinforced concrete walls of the bridge would be clad in 40mm thick stone veneer (wild stone panelling, Nero 688).
2.3 Other works would include: i. C20/25 mass concrete fill over arch between existing walls. ii. Edge of kerb to be re-aligned.
2.4 The applicant has provided further information within the application form which states that the purpose of the works is to strengthen the existing bridge by excavating down to the masonry arch and placing a concrete saddle over the arch and then construct a new deck with cantilevers to widen the bridge giving better sight lines for vehicles. The work will also provide higher parapet walls on each side to comply with current standards and provide a new pedestrian footpath on the west side of the bridge. They also state that an improved surface water drainage system is being included within the overall highways improvement scheme.
2.5 The applicants have also provided a Planning Statement which states the following: o Explains the need for the proposed improvement scheme. o The Department of Infrastructure have been implementing a programme of upgrades to the existing highway bridges on primary routes across the Island to allow for the higher weight limit of 40/44 tonnes to be safely supported and to increase the lifespan of these structures. o It is proposed to strengthen the existing bridge, prolong the life of the existing structure and improve the vehicle sight lines and pedestrian access across the bridge. o Describes the proposed works in detail (Section 3.0). o Reviews the political and planning policy considerations for the scheme. o Evaluates the design standards followed in the project conception (MFMR).
3.0 PLANNING STATUS AND POLICY 3.1 The site lies within an area identified on the Area Plan for the East as Land not zoned for development and the site is not within a Conservation area, although the bridge is part of an established road network to the south of the island. Whilst the bridge is not registered, it
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forms part of the setting for the railway station which is registered (RB 278). The site is not prone to flood risks or within a registered tree area.
3.2 The Area Plan for the East: 3.2.1 "6.13 Railway architecture 6.13.1 The route of the still-operational Isle of Man Steam Railway winds south and west from Douglas through Port Soderick and Santon Stations before continuing to its terminus in Port Erin. Given that the route, most of the rolling stock, and most of the station buildings and line- side structures are essentially as they were when the railway opened in 1874, there is obvious cultural and historic interest. The same is true (in terms of interest) for the MER."
3.2.2 Landscape Proposal 10 (for the Manx Electric Railway, the Mountain Railway and the Isle of Man Steam Railway). "For the Isle of Man Steam Railway - Views as seen from Isle of Man Steam Railway are to be preserved; development which would significantly intrude on such views will generally not be supported. Safety and continued operability will require some clear line-of-sight corridors, and these shall be maintained.
Prospective Applicants wishing to develop along these routes (which includes sites located adjacent to the boundary of the railway line or within close proximity to the transport corridors) should engage with the Department of Infrastructure 33 for advice ahead of the submission of any planning application. Prior to any decision on a planning application for which Landscape Proposal 10 is relevant, advice will normally be sought from the Department of Infrastructure."
3.2.3 Paragraph 4.7.21
"Features, vistas and landscapes which are not included here (Chapter 4) are still important. Where applications for planning approval come forward for consideration outside settlements, it is required that each design response demonstrates how the landscape is understood, how the design responds to that landscape and how colours, materials and finishes are selected that are suitable and within the contextual setting. This Chapter does not elaborate on the character of urban landscapes of the East; protection and enhancement of these features can be found in Chapter 6 - Urban Environment."
3.2.4 6.8: The historic built environment "6.8.1 Local character and key features within the built environment, such as Registered Buildings and other heritage assets play a significant role in promoting economic and social prosperity by providing attractive living and working conditions. In addition, they provide economic opportunities through tourism, leisure and recreational uses. It is therefore essential that local character is safeguarded, particularly those features which fundamentally define the historic built environment in the East. Particularly: o the buildings and structures associated with the roles of Douglas and Laxey as historic seaside resorts; o the harbours of Douglas and Laxey; o the historic infrastructure of the Steam Railway, Electric Tramway and Horse Trams; and o the historic grain of Douglas and Laxey old towns, including their street layouts, town yards, plot sizes and landscape settings."
3.2.5 Urban Environment Proposal 3 "Development proposals must make a positive contribution to local character and distinctiveness. Traditional or contemporary approaches may be appropriate, depending upon the nature of the proposal and the context of the surrounding area."
3.3 The Landscape Character Appraisal within the Area Plan Written Statement states the following about Santon (D13):
3.3.1 Landscape Strategy:
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Conserve and enhance: a) the character, quality and distinctiveness of the area, with its wooded valley bottoms and wooded horizons; b) its scattered settlement pattern; c) its Victorian garden and the railway.
3.3.2 Key Views (In part): "Views from Isle of Man Steam Railway."
3.3.3 Landscape Proposal 7 (Santon): "In cases where new development is proposed, applications must demonstrate that it can be suitably integrated into the surrounding landscape setting through reasonable mitigation measures and considering siting, colours, materials, finishes and the general scale."
3.4 Given the nature of the nature of the proposed development, it is important to consider the following policies of the strategic Plan: 3.4.1 General Policy 2 sets out Development Control Considerations, including that development will be permitted provided it, "(c) does not affect adversely the character of the surrounding landscape or townscape; (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;"
3.4.2 General Policy 3 - presumes against development outside allocated sites, other than specific exceptions which include, "location-dependent development in connection with the working of minerals and "development recognised to be of overriding national need in land use planning terms and for which there is no reasonable and acceptable alternative".
3.4.3 Paragraph 11.2.5: "The Island is fortunate to have an historic vintage rail network, which includes the Isle of Man Steam Railway, the Manx Electric Railway, the Snaefell Mountain Railway, the Groudle Glen Railway and the horse trams which run along Douglas Promenade. Development on or around the rail network should not compromise its attraction as a tourism and leisure facility or the potential for increased use as a public transport system, for example as a means of travelling to work".
3.4.4 Strategic Policy 4: Proposals for development must: (a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings(1), Conservation Areas(2) , buildings and structures within National Heritage Areas and sites of archaeological interest;
3.4.5 Transport Policy 3: New development on or around existing and former rail routes should not compromise their attraction as a tourism and leisure facility or their potential as public transport routes, or cycle / leisure footpath routes.
3.4.6 Transport Policy 5: Any improvements to the Island's highway network, including the provision of new roads, footpaths, and cycle routes, should be undertaken in accordance with the environmental objectives of this plan.
3.4.7 Transport Policy 6: In the design of new development and transport facilities the needs of pedestrians will be given similar weight to the needs of other road users.
4.0 OTHER MATERIAL CONSIDERATIONS 4.1 TOWN AND COUNTRY PLANNING ACT 1999 S16 Registered buildings: supplementary provisions
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(3) In considering - (a) whether to grant planning approval for development which affects a registered building or its setting, or (b) whether to grant registered building consent for any works, the relevant Department shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.
4.2 Planning Policy Statements: 1/01 Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man
4.2.1 POLICY RB/3 General criteria applied in considering registered building applications The issues that are generally relevant to the consideration of all registered building applications are:- o The importance of the building, its intrinsic architectural and historic interest and rarity, relative to the Island as a whole and within the local context;
o The particular physical features of the building (which may include its design, plan, materials or location) which justify its inclusion in the register; descriptions annexed to the entry in the register may draw attention to features of particular interest or value, but they are not exhaustive and other features of importance, (e.g. Interiors, murals, hidden fireplaces) may come to light after the building's entry in the register;
o The building's setting and its contribution to the local scene, which may be very important, e.g. Where it forms an element in a group, park, garden or other townscape or landscape, or where it shares particular architectural forms or details with other buildings nearby (including other registered buildings).
4.2.2 POLICY RB/5 ALTERATIONS AND EXTENSIONS In considering whether to grant planning approval for development which affects a registered building or its setting and in considering whether to grant registered building consent for any works, the Department shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses.
Registered building consent is required for the building's alteration in any way which would affect its special architectural or historic character. There will be a general presumption against alteration or extension of registered buildings, except where a convincing case can be made, against the criteria set out in this section, for such proposals.
Applicants for registered building consent for alteration or extension to a registered building must be able to justify their proposals. They will be required to show why the works which would affect the character of the registered building are desirable or necessary and they should provide full information to enable the Department to assess the likely impact of their proposals on the special architectural or historic interest of the building and on its setting. Where registered buildings are the subject of successive applications for alteration or extension, consideration will also be given to the cumulative effect upon the building's special interest as a result of several minor works which may individually seem of little consequence.
4.3 Manual for Manx Roads: Movement and Place Practitioner's Guide 4.1.1 Paragraph 10.1.4 "The Department will only support new developments that: o are designed to reduce the risk of collisions occurring and the severity of injuries if a collision does occur o are designed to be accessible to all travel modes o can be accommodated within the existing capacity of the highway network"
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4.1.2 Paragraph 10.2.36 "The measures proposed must be sufficient to accommodate or offset the impact of development on the highway network and on its surroundings. Support will be given to appropriate mitigation measures that are fully funded by the development promoter."
5.0 PLANNING HISTORY 5.1 The application site has not been the subject of any previous planning applications.
6.0 REPRESENTATIONS Copies of representations received can be viewed on the government's website. This report contains summaries only.
6.1 Representation from the Department of Infrastructure (DOI) Highways Division confirms that they 'Do not oppose' in a letter dated 5 May 2022.
6.2 Santon Commissioners have not made any comments regarding the application although they were consulted on 29 April 2022.
6.3 Manx National Heritage has made the following comments regarding the application (7 July 2022): o The scheme involves completely altering the side of the bridge which faces Santon railway station. The effect of this would be to introduce a modern engineered design which overhangs the existing arch by up to two meters, using modern materials. o They note that the station building is protected (Registered Building No. 278), and that the registration documents makes a point to referring to, and recording photographically, the station buildings visual setting. They further note that the registration documentation concludes with the remark, "With a little effort this site could be made into a timeless example of an IMR station, dating little from 1875". o They state that they cannot support the wholesale alteration of the east side of the bridge, as this unnecessarily introduces both modern materials and design to an historic setting, whilst at the same time requiring the loss of traditionally-built historical masonry. o They would prefer the retention of the parapet and its characteristic Manx stonework (complete with distinctive 'soldier' parapet) on the east side, where the bridge is visible from the station and viewed when walking to or from the station via the access road. o They do not support the use of stone veneer which would look artificial, particularly when combined with the surviving traditionally laid stonework. o The 2.64m wide pedestrian pavement in a rural setting would appear excessive. Also the 1.5m high parapet will deny anyone shorter than 1.65m a practical view of activity on the railway below.
6.4 DEFA's Assistant Registered Building's Officer has made the following comments regarding the application (8 July 2022): o The proposed deck overhand and the proposed use of a modern 'stone veneer' finish will have a significant adverse impact on the character of the bridge.
o Section 16 of the Act requires that the Department shall have special regard to the desirability of preserving the setting of registered buildings. Given the clear negative impact that this proposal would have on the setting of registered building 278, it is recommended that the application be refused.
o The proposed stone veneer is not a traditional material, and will not have any continuity with the finish of the existing bridge, and will be a very obvious modern alteration to the historic structure.
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o It is judged that the construction of a wider concrete deck on top of the existing bridge does not respect the site in terms of its form and design, adversely affects the character of the surrounding landscape and adversely affects the character of the locality.
o It is suggested that any alterations to the bridge's width or form should be focussed on the western side so that the setting of the registered building is preserved.
6.5 No comments have been received from neighbouring properties.
7.0 ASSESSMENT 7.1 The fundamental issues to consider with the current application area: i. whether the proposed alterations to the bridge will preserve the setting of the registered building or any features of special architectural or historic interest which it possesses; and ii. whether the proposed works would have any impacts on highway safety
7.2 Impact on Setting of Registered Building (GP2, SP 4, TP3, RB3 and RB 5, and Urban Environment Proposal 3 of the Area Plan for the East) 7.2.1 The railway station is of clear architectural and historic interest being the only survivor of three similar structures that existed on the Port Erin line, an original Port Erin Line wooden structure from 1875, which was taken over by the Manx Government in 1978, with the bridge forming part of the historic setting of the station which reflects the islands heritage railway status.
7.2.2 As this application proposes to alter the existing bridge (particularly the section which could be viewed from the station and forms part of the Registered building's setting) by creating a cantilever, reducing the wall thickness, and introducing materials that are not sympathetic to the existing character of the bridge and the registered building as a consequence, it is considered that the proposals clearly fail to protect or enhance the fabric and setting of the Registered Building (RB No. 278) and would fail the test within section 16 of the Act. As well, the proposal would be averse to the requirements of Strategic Policy 4 of the Strategic Plan, and Urban Environment Proposal 3 of the Area Plan for the East, as it does not respect the local character and distinctiveness of the site which would be more suited to traditional approaches and material, given the context of the surrounding area.
7.2.3 It is also considered that Policy RB/5 within Planning Policy Statement 1/01 states that applicants must be able to justify their proposals. The policy also states that applicants should provide full information to enable the Department to assess the likely impact of their proposals on the special architectural or historic interest of the building. In this case, the information within this application has not put forward any justification as to why a traditional approach which respects the setting of the registered building cannot be used to achieve the purpose of increasing the size of the existing bridge to improve functionality and safety. Moreover, the Planning statement does not recognise the bridge as being within the setting of a registered building, which indicates a clear misunderstanding of the sites context.
7.2.4 The scheme would also be averse to the requirements of Transport Policy 3 which stipulates that new development on or around existing and former rail routes should not compromise their attraction as a tourism and leisure facility, as it would diminish the status of the bridge in contributing to the setting of the registered rail station which forms part of the islands heritage, whilst promoting tourism.
7.3 Impacts on Highway safety 7.3.1 In terms of the highway safety impacts of the proposal, it is considered that the scheme would provide for a larger pedestrian area which would be sufficient for pedestrians and cycle users, given the increased width in pedestrian areas. This would also ensure that there is a
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clear segregation between vehicles and pedestrians/cyclists which would better reflect the requirements of Transport Policy 6.
8.0 CONCLUSION 8.1 Whilst the scheme would contribute to highway safety along the bridge, the proposals are considered to fail the tests of Section 16 of the Town and Country Planning Act 1999, to be contrary to the aforementioned policies within the Strategic Plan and policies RB/3 and RB/5 of Planning Policy Statement 1/01 as they will fail to protect and preserve the setting and character of the Registered Building. The application is therefore recommended for refusal.
9.0 INTERESTED PERSON STATUS 9.1 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.
9.2 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
9.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status.
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I can confirm that this decision has been made by a Principal Planner in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded Interested Person Status.
Decision Made : Refused Date: 03.10.2022
Determining officer
Signed : J SINGLETON
Jason Singleton
Principal Planner
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