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Application No.: 22/01264/B Applicant: Department Of Infrastructure Proposal: Construction of Douglas Promenade Wave Overtopping Wall Site Address: Douglas Promenade And Loch Promenade Adjacent To Bottleneck Carpark Douglas IM1 2RF Planning Officer: Mr Hamish Laird Photo Taken: 25.05.2023 Site Visit: 25.05.2023 Expected Decision Level: Planning Committee Recommended Decision: Permitted Date of Recommendation: 31.05.2023
C : Conditions for approval N : Notes attached to conditions
Reason: To comply with article 14 of the Town and Country Planning (Development Procedure) (No2) Order 2013 and to avoid the accumulation of unimplemented planning approvals.
Reason: For the avoidance of doubt, as the application makes reference to a potential future extension to the height of the wall by an additional 0.6 metres and this would require a separate application.
Reason: For the avoidance of doubt, as the application makes reference to a potential future extension to the length of the wall and this would require a separate application.
This application has been recommended for approval for the following reason.
Overall it is concluded that the planning application accords with the provisions set out in Strategic Policies 1, 4 and 8; Spatial Policy 6; General Policy 2, Environment Policies 10, 11, 12, 13, 22, 35, 41, 42 and 43 of the Isle of Man Strategic Plan 2016.
Plans/Drawings/Information; This approval relates to the following plans and information:
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:
Department of Infrastructure (DOI) Flood Risk Management Division. _____________________________________________________________________________
THE APPLICATION IS BEFORE THE PLANNING COMMITTEE AT THE REQUEST OF THE DIRECTOR OF PLANNING AND BUILDING CONTROL
1.1 The site comprises a 180m section of Douglas Promenade between the slipway at the Sea Terminal to the (Snack Shack) Café on the Promenade adjacent to the beginning of the Sunken Gardens and will incorporate architectural features to soften its visual impact identical in nature to the planning application that was approved for the section of wall between the War Memorial and The Empress Hotel.
1.2 The site lies within the Douglas Promenades Conservation Area. This covers the length of Douglas seafront from the Victoria Pier at the harbour to the south, to the Manx Electric Railway Depot and Museum in the north bounded by Imperial Terrace, Onchan. The Conservation Area includes the Sunken Gardens, existing sea wall and railings. THE PROPOSAL
2.1 The full application proposes the construction of a Wave Overtopping Wall along a 180m section of Douglas Promenade between the slipway at the Sea Terminal to the Café on the Promenade adjacent to the beginning of the Sunken Gardens. The construction of the wall will consist of a reinforced concrete wall tied into the top of the existing concrete sea wall. Nonreturn flap valves would be placed close within horizontal rectangular slots close to ground level to allow the one-way return of water to the sea. - 2.2 At 1.2m high the wall will allow people to see over the top and out to sea. This height is not the full height that will be required if climate change continues as expected but it has been designed so that an additional 0.6m can be added by future generations when required. It is anticipated that the wall will eventually be extended the full length of the promenade. However, this scheme is only for wave overtopping for the limited section as described above. - 2.3 Subject to planning approval the construction of the wall will be programmed to be sympathetic with the programme for the section between The War Memorial and The Empress Hotel. The wall will incorporate architectural features to soften its visual impact identical in nature to the planning application. The construction programme will be approximately two months and disruption to the public is expected to be minimal. - 2.4 The current Ref: 22/01264/B and previously approved Ref: 19/00755/B proposals do not include the sea front wall to the front of the Sunken Gardens between the (Snack Shack) Café and the War Memorial, because the Sunken Gardens act as a Sustainable Drainage System (SuDS) feature in this location along the Loch Promenade. DIRECTLY RELEVANT PLANNING HISTORY
3.1 The proposals are a reflection of the previously approved application Ref: 19/00755/B for the construction of 500m long reinforced concrete wall 1.2m in height anchored to the existing sea wall to reduce wave overtopping along Harris Promenade, Douglas. - 3.2 Previously, application Ref: 18/00956/B sought permission to construct a wall to protect against wave overtopping along a 507 metre section of Douglas Promenade, as part of a wider approach to protect Douglas. This application included a Planning Statement of Case and an Environmental Impact Assessment. The wall was intended to offer localised protection to the horse tram operation in the area of the War Memorial, which is set to become a tram turning area on the new promenade layout. The development which was the subject of this application was intended to be the first stage of further works (the application outlined areas elsewhere for works, although these did not form part of the application and so were not considered at that time). This permission was not implemented, and has since been superseded by the Ref: 19/00755/B permission. - 3.3 The Statement of Case submitted with the 19/00755/B proposals noted the previous refusal (see planning history) and a number of changes were subsequently made comprising: "- Additional Artwork has been incorporated into the wall;
OTHER RELEVANT PLANNING HISTORY 18/00003/B - Re-construction and repositioning of highways and footways on Loch and Harris Promenades, including associated street furniture and the upgrading and refurbishment of all drainage and statutory service infrastructure. Works to include replacement of horse tramway double track with single track in a zone on the seaward side of the new highway alignment Douglas Promenade from Sea Terminal, Loch Promenade and Harris Promenade, Douglas, Isle of Man - Permitted - 16/2/2018. This scheme has been implemented.
16/00379/B - Re-construction of the highway and footpaths and creation of a low speed streetscape on and along Loch and Harris Promenades, and creation of an area to provide seating, sculpture, lighting, display screens, bike storage areas, bus shelter and landscaping within Harris Promenade - Douglas Promenade From Sea Terminal, Loch Promenade And Harris Promenade, Douglas, Isle of Man - Withdrawn - 25/7/2016.
15/00594/B - Re-construction of the highway and footways to create a low speed streetscape, re-location of horse tram tracks on to the promenade walkway, re-surfacing the promenade walkway and creation of a cultural quarter near Gaiety Theatre - Douglas Promenade from Peveril Square to Strathallan Crescent, Douglas, Isle of Man - Permitted - 21/3/2016. (These works ran for the length of the Promenade).
13/91533/B - Douglas Promenade improvements Phase 2 - Loch Promenade from Peveril Square to Regent Street, Douglas, Isle of Man - Permitted - 29/4/2014.
12/01327/B - Douglas Promenade improvements Phase 1 - Sea Terminal Building to Royal Bank of Scotland Buildings, Loch Promenade, Douglas, Isle of Man - Permitted - 24/12/2012.
08/00860/B - Installation of an information board - Sea Wall, Loch Promenade, Douglas, Isle of Man - Withdrawn - 13/5/2008.
84/00861/D - Erection of plywood advertisement panels (2 per shelter), 10 Shelters sited along Douglas Promenade, Douglas at 10 Shelters sited along Douglas Promenade, Douglas Withdrawn - 17/8/1984.
84/00453/B - Replacement of ten public shelters, Douglas Promenade, Douglas - Permitted 1/1/1994.
4.0 THE DEVELOPMENT PLAN - 4.1 In terms of the current land use designation the site is identified as being "The Promenade" on the Ares Plan for the East Map 5 Douglas. The site is also within the Douglas Promenades Conservation Area. - 4.2 Due to the land use designation of the site and the type of development proposed the following policies are recommended to be relevant for consideration:ISLE OF MAN STRATEGIC PLAN - 4.3 Strategic Aim states: "To plan for the efficient and effective provision of services and infrastructure and to direct and control development and the use of land to meet the community's needs, having particular regard to the principles of sustainability whilst at the same time preserving, protecting, and improving the quality of the environment, having particular regard to our uniquely Manx natural, wildlife, cultural and built heritage." - 4.4 Strategic Policy 1 states: "Development should make the best use of resources by:
4.5 Strategic Policy 4 states: "Proposals for development must:
Buildings(1), Conservation Areas(2), buildings and structures within National Heritage Areas and sites of archaeological interest;
4.6 Strategic Policy 8 states: "Tourist development proposals will generally be permitted where they make use of existing built fabric of interest and quality, where they do not affect adversely environmental, agricultural, or highway interests and where they enable enjoyment of our natural and man-made attractions." - 4.7 Spatial Policy 6: "The strategic roles of Ronaldsway Airport and Douglas Harbour as principal gateways to the Island will be protected and enhanced." - 4.8 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:
4.9 "7.12.5 The Coastline Management Act 2005 has now been brought into operation. The aims of the Act are to:
4.10 Environment Policy 10 states: "Where development is proposed on any site where in the opinion of the Department of Local Government and the Environment there is a potential risk of flooding, a flood risk assessment and details of proposed mitigation measures must accompany any application for planning permission. The requirements for a flood risk assessment are set out in Appendix 4."
4.12 Environment Policy 11 states: "Coastal development will only be permitted where it would not: i) increase or transfer the risk of flooding or coastal erosion through its impact on natural coastal processes; ii) prejudice the capacity of the coast to form a natural sea defence; and iii) increase the need for additional coast protection works except where necessary to protect existing investment or development." - 4.12 Environment Policy 12 states: "New coastal defence works must not have an unacceptable impact on the character, appearance, ecology, archaeology or natural processes of the coastal environment."
4.14 Environment Policy 13 states: "Development which would result in an unacceptable risk from flooding, either on or off-site, will not be permitted." - 4.15 Environment Policy 35 states: "Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area, and will ensure that the special features contributing to the character and quality are protected against inappropriate development." - 4.16 Environment Policy 41 states: "The Department will require that archaeological evaluations be submitted prior to the determination of proposals affecting sites of known or potential archaeological significance. In cases where remains are affected but preservation insitu is not merited, the Department will expect to secure excavations and/or recording in advance of construction work either by the imposition of suitable conditions attached to a planning permission or through a formal agreement entered into with the developer." - 4.17 Environment Policy 42 states: "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." - 4.18 Environment Policy 43 states: "The Department will generally support proposals which seek to regenerate run-down urban and rural areas. Such proposals will normally be set in the context of regeneration strategies identified in the associated Area Plans. The Department will encourage the re-use of sound built fabric, rather than its demolition." - 4.19 Transport Policy 1 states: "New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes." - 4.20 Transport Policy 2 states: "The layout of development should, where appropriate, make provision for new bus, pedestrian and cycle routes, including linking into existing systems."
4.15 Transport Policy 3 states: "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."
4.21 Transport Policy 4 states: "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." - 4.22 Transport Policy 5 states: "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." - 4.23 Transport Policy 6 states: "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."
4.24 Policy CA/2 - Special Planning states: "When considering proposals for the possible development of any land or buildings which fall within the conservation area, the impact of such proposals upon the special character of the area, will be a material consideration when assessing the application.
"Where a development is proposed for land which, although not within the boundaries of the conservation area, would affect its context or setting, or views into or out of the area; such issues should be given special consideration where the character or appearance of a conservation area may be affected."
4.25 VM5: Improve connection / crossing at Church Marina Road to Villa Marina / Gaiety Complex states: "Addressing this linkage between the Strand Street area and the Villa Marina area is crucial to knit this development into the retail area more successfully. A redesign of the space could address the crossing of this busy junction, and enable ease of pedestrian movement between the two areas." - 4.26 VM7 Improve pedestrian permeability between Villa Marina & Gaiety Theatre to The Promenade states: "A scheme of improvements is currently proposed for the Promenade, the initial phase has been implemented and a further phase now has planning permission. It is important that future phases consider the location of crossing points and traffic speeds along the Promenade; perhaps looking at the potential for 'super crossings' to support movement." - 4.27 TP4 Creation of Promenade Activity Attractors states: "Utilising the 'Living Promenade' proposals, public art and landscape features to seize the missed opportunity for the Marine Gardens. Improving environment and facilities for existing users (cyclists, walkers, children & visitors). This could be part of town circuit linking to Villa Marina Gardens and Falcon Glen. The Attractors are part of the ambition to activate the Promenade space, harnessing the potential."
4.23 TP6 Improving connections across the Promenade to link between Strand Street and the Promenade states: "As highlighted earlier, the benefits of supporting linkages to Strand Street would be symbiotic, in that both attractions will support movement to the other through well considered crossing points and creating environments that support and prioritise pedestrians."
4.28 TP7 Explore potential to extend the Tram states: "The electric tram could be extended along the Promenade to provide both a commuter connection and tourist attraction. The Tram could provide an alternative mode of transport for the town to reduce car activity."
5.1 Douglas Borough Council has commented on the application 4 times. Initially, a holding reply was received on 25/10/22. On 18/11/2022, Douglas Borough Council wrote in Support of the application. The Council commented:
"Following consideration of the above planning application at a meeting of the Council's Environmental Services Committee held on the 15/11/22 I can advise that the Committee has resolved to support the application.
Although the Committee supports this application and recognises the potential benefits the proposed wall will bring to this small 180m part of the Promenade, it considers that there will still be a large part of the Promenade that will remain unprotected.
The Council therefore wishes to express its extreme disappointment that there are still no plans to replace the existing railings and extend the sea protection wall between the Jubilee Kiosk and the Marine Gardens Kiosk close to the Douglas Promenade War Memorial on Harris Promenade, a section of Promenade that has already suffered major wave damage. The lack of an overtopping wall along this section of the Promenade is a serious concern going forward leaving many areas still vulnerable to wave damage."
On 9/3/23, Douglas Borough Council commented further re-iterating its Support for the application. The Council commented:
The above planning application was previously considered by the Council's Environmental Services Committee at a meeting held on the 15/11/22 when it was resolved to support the application.
We have now been notified that additional information has been provided by the applicant that has required the application to be advertised once again.
We note the additional information which is welcomed and having now had the opportunity to review the application the Council continues to support the proposed development.
As stated within our previous correspondence the Council is still disappointment that there are no plans to replace the existing railings and extend the sea protection wall between the Jubilee Kiosk and the Marine Gardens Kiosk close to the Douglas Promenade War Memorial on Harris Promenade, a section of Promenade that has already suffered major wave damage. The lack of an overtopping wall along this section of the Promenade is a serious concern going forward leaving many areas still vulnerable to wave damage.
On 17/3/23, Douglas Borough Council commented further stating that it had no objections to the planning application.
5.2 On 19/10/22, DOI Highway Services commented that: "After reviewing this Application, Highway Services HDC finds it to have no significant negative impact upon highway safety, network functionality and /or parking after works are completed".
On 9/3/23, DOI Highway Services commented that: "Highways Development Control notes the additions uploaded on 8 March 2023 and continues to not oppose this proposal."
5.3 Director of Department of Infrastructure (DOI) Flood Risk Management Division advised that the Department did not oppose the application. It commented that: "FRM would suggest that there is a maintenance plan in place to keep the scuppers clear to allow overtopping to flow back on to the sea." - 5.4 DEFA Fisheries Division (31/3/23) commented: "This application and has been checked by Fisheries Officers. As the proposed works are in close proximity to the coastal waterline, precautions will be needed to reduce the possibility of harmful materials such as concrete or washings entering the river. DEFA Fisheries Division have no objection to the proposed development, provided that suitable precautions are followed and there is no disturbance of the coastal waterline." - 5.5 No neighbour representations had been received by the Report Drafting stage.
6.1 It is considered that the main considerations of this planning application are:
6.2 The main aims of this proposal are in line with those of the Ref: 19/00755/B proposals, are to improve the appearance, structure, and functions of the entire Promenade for all users, and to minimise flood risk in the event of exceptional weather conditions and to minimise the potential for 'overtopping' by the sea. - 6.3 The current land use designation of the site is defined on the area plan for the east as the promenade and within the settlement boundary of Douglas Town Centre. It is therefore considered that the broad principle of the works is acceptable because they would assist in protecting the public highway from flooding by the sea and thus aid the flow of both traffic and pedestrian movements along the Promenades. - 6.4 It is noted that all recent planning applications (Refs: 19/00755/B, 18/00956/B, 15/00594/B, 13/91533/B, 12/01327/B) have been considered by an Independent Inspectors (with decisions made by CoMIN) and the decision makers have agreed with the Inspector's conclusion that the regeneration of the existing run-down Promenade was of benefit to the community and represented an enhancement of the Conservation Area and Promenade. - 6.5 Environment Policy 42 indicates (inter alia) that new development must be designed to take account of the particular character and identity of an area, in terms of buildings and landscape features of the immediate locality. 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, with open or green spaces to be preserved identified in Area Plans. It is noted that the pedestrianised parts of the Promenade and the Sunken Gardens would not be affected by this proposal. - 6.6 Environment Policy 43 indicates that support should generally be given to proposals which seek to regenerate run-down urban areas. Previous Planning Inspectors, when considering some of the above proposals, noted that it was clear that while the Promenade had a number of significant strengths (such as the sweep of Victorian properties), the quality and condition of some of the public realm has in the past been judged to be in poor condition which detracted from the overall quality of the area. Subsequent to the history of recent appeal approvals for the Promenades, improvements have been made in terms of (inter alia) new lighting columns, with coloured lighting along the promenade, new road and pavement surfacing, new pedestrian crossings, the introduction of a 20 mph zone; and, the two 'textured' surface level
"The existing highways and streetscape finishes and street furniture are in very poor condition and neither enhance nor preserve the character or appearance of the Promenade Conservation Area. The proposed works would certainly improve the character and appearance of this 'gateway area' and the surface materials and finishes, comprising high to medium quality natural stone, asphalt and concrete would provide a much improved streetscape."
6.8 When the Inspector for Phase 2 considered the application, he made the following comments in relation to the principle and visual appearance of the existing area:
"…the case for the Douglas Promenade regeneration programme, its overall form and finishes were I think established by the approval of Phase 1. The scheme had widespread public support during prior consultations. It barely needs saying that the Promenade, as well as being a key traffic route, provided Douglas with an iconic, vibrant sea-front. It also barely needs saying, as may be readily seen, that this highway is in poor condition, timeworn and at the very least requires substantial structural, drainage and surfacing works. Highways Division are to be commended for seeing this as an opportunity also for upgrading and refurbishment, with high quality finishes, improved pedestrian crossings and relocating the horse trams clear of today's road traffic. There has been no objection, at least in relation to Phase 2, regarding the scheme considered broadly."
6.9 Whilst neither of the Phase 1 and Phase 2 schemes included land comprising the current application site, the Inspector's comments set out above are considered relevant in the assessment of the current application. - 6.10 The Inspector for the previously refused scheme (15/00594/B) also commented on the principle of the development:
"The principle of refurbishment of the whole of the Promenade is accepted by all parties although some objectors are opposed to the principle of providing roundabouts and others question the overall extent, costs and need for the works involved. Whilst some of the points made relating to how the highways will operate can be relevant, the matter of overall cost and the extent to which works are actually required are matters for DOI as the applicant."
6.11 In light of the above, it is considered that the overall principle of the works proposed to the 180m length of the sea wall along Loch Promenade covered by this application, are acceptable.
6.12 The entire application site is within a Conservation Area and therefore requires careful consideration against Environment Policy 35. This policy requires any development to either preserve or enhance the character or appearance of the Conservation Area, and ensure that
6.15 The comments from the Conservation Officer in relation to the Ref: 18/00956/B application (and as also advised in the Ref: 19/00755/B, Committee Report) are noted. Subsequent to these previous applications, and bearing in mind the shorter section of wall applied for (180m as opposed to 507m), the application draws on the previously submitted detailed analysis of heritage impact and an explanation of how the design responds to the historic context. It is noted that it is still the case that there are currently open views out across the bay via the sections of railings that are interspersed at regular intervals between concrete sections that have 'castle' designs incorporated into them, and which are no more than 4 feet (1.2m) high as the maximum height required by the Douglas Foreshore and Town Act 1886. This length of existing wall pie and railings area would remain where it lies along the length of the Sunken Gardens until such time as a future scheme to infill the Sunken Garden gap comes forward for consideration. - 6.16 As with the previous proposals, this one would introduce a solid structure and, therefore, would materially alter the character of the view from the Promenade towards the sea. It is noted that the proposal for viewing platforms as part of the 19/00755/B approved scheme will mitigate this to some extent. Nevertheless, those who are sitting on the Loch Promenade Benches; or who are wheelchair users; or, in pushchairs, will not be able to experience views of the sea and Douglas Bay that are currently available through the sections of railings along this 180m stretch of Douglas' Loch Promenade. On balance, it is concluded that the proposal will have a negative impact on the character and appearance of the Conservation Area, but that heritage impacts have been adequately identified and mitigated as far as is practicable within the constraints of the proposed flood solution. The Impact on the use of the Promenade - 6.17 The proposal would not impact on the amount of area which is usable. It is considered that the concerns raised by Douglas Borough Council in relation to the previous scheme in relation to the slipway and lifebelts/flag poles have been resolved for that scheme. They do not arise here owing to the relatively short (180m) length of works proposed to the existing wall. In these respects the proposal complies with the relevant policies and direction of travel of the Area Plan.
6.18 Whilst the proposed mitigation (viewing areas) and firmer justification of the most recent application are noted, it is still considered that the proposal would impact on the ability of some of those people using the space to enjoy sea views and in this aspect is considered contrary to GP2(e) and weighs against the application. Nevertheless, it is considered that the benefits of the scheme in terms of overtopping mitigation and wider flood protection of this part of the Loch Promenade outweigh these concerns. Traffic, Pedestrians, and Parking - 6.19 The proposals involves the construction of a Wave Overtopping Wall on the line of the existing Loch Promenade wall adjoining the beach and would not involve any implications for either traffic or pedestrians owing to the limited nature of the works. - 6.20 The existing Bottleneck car park would remain and be unaffected by the proposed works. Street Furniture - 6.21 Not all the information is currently provided regarding street furniture (street lighting, benches, bins & cycle stands etc.), but in a previous regeneration project, namely RamseyParliament Square, a planning condition was attached which required full details of street furniture prior to any works commencing, which also indicates the location of any such furniture. There are areas which have been dedicated for additional street furniture located along the Promenade; however, the actually details have not been provided. However, some seating (benches incorporating planters within) has been provided which are located at certain locations (namely near access to sunken gardens). Further, the applicants are working with Douglas Borough Council to accommodate new highway lighting scheme to be incorporated into the proposals, albeit the details of the lighting are not yet finalised. OTHER MATTERS - 6.22 Comments have been made in relation to cycle lanes not being provided. It is understood that cyclists will still be able to utilise the existing Promenade Walkway to cycle along, which is currently the case and is not proposed to change. Further the applicants have advised the following in response to the comments being received:
6.23 In terms of further comments relating to sea walls/flood protection, the submitted statement indicates that the design of the scheme does allow for such provisions to be accommodated if needed. However, these would be subject to a further planning approval.
7.1 In conclusion, it is recommended that the planning application be approved on the grounds that the proposed development would be in accordance with the Isle of Man Strategic Plan (June 2016); the Area Plan for the East; the Central Douglas Master Plan; and, The Douglas Foreshore and Town Act 1886. - 8.0 INTERESTED PERSON STATUS
8.1 By virtue of the Town and Country Planning (Development Procedure) (No 2) Order 2013 (Article 6(4), the following persons are automatically interested persons:
8.2 The Planning Committee must determine:
8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers (Director of Environment Safety and Health) within the Department make comments in a professional capacity they cannot 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: 19.06.2023
Signed : H Laird Presenting Officer
Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report).
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