**Document:** Planning Supporting Statement
**Application:** 11/00527/A — Approval in principle to replace existing industrial / commercial units with new office building
**Decision:** Permitted
**Decision Date:** 2011-10-17
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/875-braddan-bridge-works-site-replacement/documents/1150054

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# Planning Supporting Statement

## dandara commercial limited

Approval in Principle to Replace Vacant Commercial/Industrial Units with a New Office Building, Bridgeworks Site, Castletown Road, Douglas

## Contents

1.0 Introduction
2.0 The site
3.0 Planning history
4.0 Planning policy context
5.0 The proposal
6.0 Summary

### Appendices

1. The approval notice for PA 04/01417

## 1.0 Introduction

1.1 This application seeks planning approval in principle for the development of a site between Castletown Road and the River Douglas with a new office building. The site is currently occupied by vacant commercial premises known as Bridgeworks, which have most recently been used as tyre/exhaust workshops.
1.2 Whilst this application seeks planning approval in principle only, consultation has previously taken place in respect of a detailed office scheme for the site. The consultees in that instance, who in general raised no concerns in respect of the principle of redeveloping the site, included;

- Local residents
- The MHKs for South Douglas
- Douglas Development Partnership
- Department of Infrastructure Planning
- Department of Infrastructure Highways
- Isle of Man Water and Sewage Authority
- Officers of Douglas Town Council (drainage)
- Isle of Man Constabulary Architectural Liaison Officer
1.3 This application simply seeks confirmation that, in principle, the redevelopment of the site with an office scheme is acceptable. As such it does not seek approval for a building of a particular size or design, which are amongst the issues that would form the subject of a subsequent application which seeks approval to Reserved Matters. This application does however include information which is sufficient to demonstrate that the site can be accessed safely and that a redevelopment scheme will take account of flood risk.

#### 2.0 The Site

2.1 The application site is located between Castletown Road and the River Douglas, and is immediately to the west of the Bridge Road/South Quay roundabout. It is occupied by low-grade commercial buildings, which were

most recently used as tyre/exhaust workshops but are currently vacant. The site is linear in form and has two points of vehicular access from Castletown Road. As the highway passes the site it slopes upwards towards the Bridge Road/South Quay roundabout, and as such the floor level at the eastern end of the site is below the level of the highway.

2.2 The River Douglas runs alongside the northern site boundary, with the newly constructed Quay West residential development on the opposite riverbank. Adjacent to the site on the southern side of Castletown Road are a mix of uses — commercial units, multi-storey car parking, and residential property. The relationship of the proposed scheme to these adjacent uses is illustrated in the application drawings, which include sections through the site and its surrounds.

3.0 Planning History

3.1 Planning approval in principle has previously been granted under PA 04/01417 to develop the application site with a scheme of apartments¹. An application which sought detailed approval for an office scheme was submitted in December 2010 under PA 10/01889 but was immediately withdrawn.

3.2 Quay West (across the river to the north) has been the subject of a number of approvals, the most recent being PA 10/00088. Subsequent phases of residential development to the west of Quay West are proposed under PA 09/01386.

4.0 Planning Policy Context 4.1 The planning policy context for the application is set out in the Isle of Man Strategic Plan (IoMSP) and the Douglas Local Plan 1998. 4.2 The Isle of Man Strategic Plan

4.2.1 The IoMSP was adopted by the Department in June 2007 and approved by Tynwald the following month, and is intended to provide "the strategic and

¹ The approval notice for PA 04/01417 is attached at Appendix 1

3

general policy framework within which provision will be made for development and conservation needs for the period 2001-2016". Together with Area (and Local) Plans the loMSP forms a Development Plan as required by the 1999 Town and Country Planning Act. It is made clear in the Plan that "in the case of any inconsistency between the provisions of the Strategic Plan and the provisions of an Area Plan, whichever came into force later will prevail", with the Strategic Plan being the most recent in this instance.

#### 4.2.2 Amongst the Strategic Objectives of the Plan

Amongst the Strategic Objectives of the Plan it is indicated that resources should be protected, used, and re-used in an efficient and economic way, and that most new development should be guided towards existing settlements in order to make "the optimum use of existing and planned infrastructure and services". This accords with the stated intention to promote urban regeneration and the re-use of derelict and redundant sites. The Plan also seeks to reduce the need for travel, "especially by private car", and states that new housing and employment should be located "close to existing public transport facilities and routes, or where public transport facilities are, or can be improved, thereby reducing the need to use private cars and encouraging alternative means of transport". It is also stated amongst the Strategic Objectives that the viability, vitality and diversity of the economy should be maintained and improved by enabling improved employment opportunities, and that the Plan should seek to ensure that sufficient land and property in terms of location, size and type is available for employment purposes.

#### 4.2.3 The Strategic Policies which flow from these objectives

The Strategic Policies which flow from these objectives emphasize the need for development to make the best use of resources by, amongst other things, "optimising the use of previously developed land, redundant buildings, unused and under-used land and buildings, and re-using scarce indigenous building materials", as well as ensuring the efficient use of sites and being located so as to utilise existing and planned infrastructure, facilities and services. New development should have regard to the use of local materials and character, and should be designed so as to make a positive contribution to the environment of the Island. The Plan goes on to state that "major employment-generating development should be located in existing centres on land zoned for such purposes and identified as such in existing Local or new Area Plans". It also requires new development to be located and designed so as to promote a more integrated transport network, in order to minimise journeys

(especially by private car), make the best use of public transport, not adversely affect highway safety, and encourage pedestrian movement.

#### 4.2.4
The IoMSP includes an Island Spatial Strategy (ISS) which is intended to guide the physical development of the Island up to 2016. The Island is divided into North, South, East and West regions and the ISS seeks to "promote a balanced and equitable pattern of sustainable development across the Island". Spatial Policy 1 states that "The Douglas urban area will remain the main employment and services centre for the Island".

#### 4.2.5
General Policy 2 of the Plan identifies standards of development that should be complied with, which include criteria in respect to building scale and appearance, impact upon landscape or townscape, amenity standards for local residents, highway matters, flood risk, personal safety/security, and energy consumption. Environment Policies 7, 10, and 13 refer to watercourses and flood risk respectively, indicating that certain applications may need to be accompanied by a flood risk assessment. Environment Policy 36 states that development which is outside of a Conservation Area but close to the boundary must not detrimentally affect important views into and out of the Conservation Area. Environment Policy 42 requires the design of new development in existing settlements to take account of "the particular character and identity, in terms of buildings and landscape features, of the immediate locality".

#### 4.2.6
Business Policy 1 of the Plan encourages the growth of employment opportunities throughout the Island, whilst Business Policy 7 states that new office floor space should be located within town and village centres on land which is zoned for the purpose. Business Policy 8 requires new office buildings to respect the scale and character of adjoining and nearby buildings, and to accommodate parking space in accordance with the standards of the Plan.

#### 4.2.7
Transport Policy 1 of the Plan states that new development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle, and rail routes. Transport Policy 4 seeks to ensure that new and existing highways are capable of safely accommodating the vehicle and pedestrian journeys created by development. The supporting text

which precedes Transport Policy 7 indicates that the long term target is to reduce the level of car parking required for town centre developments and to seek more sustainable staff and visitor transport plans. Transport Policy 7 requires that parking provision in all new development meets the Department's standards, which is shown at Appendix 7 of the Plan to be 1 space for every 50 square metres of nett office floor space. The Plan makes provision however for standards to be relaxed under certain circumstances, which includes where the development is within a reasonable distance of an existing or proposed bus route and it can be demonstrated that a reduced level of parking will not result in unacceptable on-street parking in the locality. Transport Policy 8 requires all applications for major development to be accompanied by a Transport Assessment.

## 4.3 The Douglas Local Plan 1998

4.3.1 The extant Isle of Man Planning Scheme (Douglas Local Plan) Order 1998 was approved by Tynwald in December, 1998, and as a reflection of its use at that time the site is shown on the Central Area Map as an area of Light Industrial Use. Policies D/O/P1 and D/O/P2 of the Plan seek to restrict new office development to the town centre, although some exceptions are noted.
4.3.2 Paragraph 7.2 of the Plan defines the Central Area of Douglas, in transport terms, as an area which broadly equates to that shown on the Central Area Map. Subsequent paragraphs consider how the parking requirements of new office development will be met, stating that "In order to reduce car parking in relation to new office development and consequently a reduction in private car movement it is felt that constraints in relation to such provision should be considered". It goes on to suggest that application of the current standard (1 space per 50 sq.m) can result in the lower levels of development being dominated by the car to the detriment of building design and street character, and that relaxation of the standard may bring benefits in terms of development potential and the efficient use of land.
4.3.3 Policy D/CP/P1 (para 7.12) of the Douglas Local Plan indicates that the reappraisal of parking standards should, where relevant or achievable, be based upon site characteristics and constraints, the level of provision desired by the developer/occupier, and the maintenance of the current standard. It

goes on to suggest that any shortfall in provision should be accommodated in "peripheral surface or multi-level car parks" which are in close proximity to main roads and allied to a regular public transport system. Policy D/CP/2 essentially repeats this latter point. Policy D/CP/P3 states that service areas for vehicular collections/deliveries should be provided within all new developments unless specific circumstances dictate otherwise. These provisions have in any event been superseded by the parking standards and guidance of the Isle of Man Strategic Plan.

## 5.0 The Proposal

5.1 The application seeks planning approval in principle for the redevelopment of the site with a new office building, to replace the low grade commercial buildings which currently occupy the site. Approval is not sought for a building of a particular size or design, which are amongst the issues that would form the subject of a subsequent Reserved Matters application.
5.2 The site is within the Central Area of Douglas as identified in the Local Plan, and is close to areas of established office use such as Clinch's Yard and Athol Street. It is also adjacent to Quay West, which includes an office unit on its southern side. As a redundant/under-used site within the central area of Douglas its redevelopment accords with objectives and policies of the loMSP, and its location in close proximity to offices, services and other facilities will ensure that redevelopment with an office building will not prejudice the provision of such within other central areas. The Local Plan designation of "Light Industrial" reflects the site's use at that time, and the granting of planning approval in principle to develop the site with apartments has established that its land-use zoning may be set aside to enable its redevelopment for other purposes. It should be noted that the Riverside Apartments on the southern side of Castletown Road (opposite the site) also replaced a commercial building within an area designated for Light Industrial use.
5.3 The application seeks to demonstrate that, in principle, the site is capable of being redeveloped with an office scheme that can be safely accessed/egressed without detriment to new or existing highway users. The detailed scheme which was submitted in December 2010 but subsequently

withdrawn was accompanied by a Transport Assessment which considered a number of relevant issues;

- In accordance with TA79/99, Traffic Capacity of Urban Roads, the traffic carrying capacity of a road such as Old Castletown Road, with a 6.7/7.3 metre wide carriageway and on-street waiting prohibited at all times of the day, is likely to be of the order of 2,500 vehicles per hour. Castletown Road is therefore typically operating at some 60% of its traffic carrying capacity during the morning and evening peak periods and less at other times of the day. There are therefore gaps in its traffic flow into which vehicles from side roads or accesses can emerge. Delays to traffic on Old Castletown Road, in the vicinity of the application site are caused by junctions rather than its link capacity and the mini-roundabout at the junction of Bridge Road and South Quay has this effect whilst also reducing the speed of traffic as it travels along the site frontage.

- A Travel Plan will be prepared which will encourage people employed within the building to walk, cycle or use public transport rather than private cars and an area within any redevelopment scheme can be provided to store cycles so as to encourage their use.

- In the case of the previous detailed scheme, which proposed to provide 14 no. spaces on site, it was shown that the flows in the vicinity of the proposed development would increase by approximately 1% at peak times of day. This is less than the daily variation in flows which occur under normal circumstances and will not be material or noticeable. In addition, the traffic should not all be considered to be new to the highway network because the existing premises could generate some traffic in their own right and hence the impact of the traffic generated by the proposed development will be further reduced. The operation of the proposed site access with Old Castletown Road was analysed using the PICADY 5.1 program and the predicted morning and evening peak hour flows. It was also assumed that vehicles waiting to turn right into the car park access would prevent other traffic from travelling in a westerly direction along Old

Castletown Road until that right turn manoeuvre is complete. The results of the analyses show that the maximum RFC values would be 0.018 and 0.051 during the morning and evening peak periods respectively and that this would result in delays of some 16 seconds for vehicles waiting to turn right from Old Castletown Road into the development during the morning peak period and some 10 seconds for vehicles waiting to turn right out of the car park access into Old Castletown Road during the evening peak period. The analyses also showed that this will not cause queues of traffic to form behind vehicles which may be waiting to turn right into the development even though the analysis assumes that they will prevent the through movement of any other traffic. In practice, cars and light vans will be able to pass other vehicles which are waiting to turn right and they will not, therefore, cause unacceptable delays to traffic on Old Castletown Road.

Old Castletown Road is a Primary Distributor type of road and in accordance with the Department of Transport Policy regarding Access to the Highway, visibility splays at proposed accesses should be based on the advice contained in PPG13, Transport, 1994. Visibility splays along Old Castletown Road of 2.7 x 90.0 metres to the west and 2.7 x 60.0 metres to the east, towards the roundabout junction, are therefore proposed at the car park access as shown on the submitted site plan 2344 APL/111. That to the west passes over adjoining Department of Transport land and boundary wall which is some 1.25 metres high. The wall will therefore be reduced to 1.0 metre in height or rebuilt behind the visibility splay, between the gateway and the proposed development, so that the splay as proposed will be effective. The 90.0 metre distance will allow drivers of vehicles emerging from the car park to see vehicles approaching from their right, along Old Castletown Road, in time for them to judge whether it is safe to join that road or wait until any approaching vehicles have passed and therefore it accords with the recommendations of PPG13 for roads with 30mph speed limits or for roads where the measured speeds do not exceed 37.5 mph. That to the east, to the roundabout, is measured to the nearside of the exit lane from the roundabout and will allow drivers of vehicles emerging

from the car park to see vehicles leaving the roundabout in time to judge whether it is safe to join the road or wait until they have passed. The 60.0 metre major road dimension is equivalent to 63.0 metres when used with a minor road dimension of 2.4 metres and in accordance with PPG13, these distances are appropriate for major road speeds of up to $25-30 \mathrm{mph}$. This is greater than the measured range of typical speeds of vehicles leaving the roundabout. The visibility splays as proposed also allow drivers of vehicles approaching the car park access from both directions along Old Castletown Road to see vehicles which may be emerging in time for them to slow down or stop safely if that should be necessary. They therefore comply with the recommendations of PPG13 and are not reduced to such a level that danger is likely to be caused.

- It is likely that any new building will be serviced by smaller vehicles, including those which are the size of 'Transit' vans and which are typically used for deliveries, which will be able to enter and leave the building in forward gear because a turning area can be provided within the site to accommodate vehicles up to that size. Larger vehicles will also however be able to service the building from a proposed lay-by on Old Castletown Road in the vicinity of the access to the site as shown on the submitted site plan. This lay-by would take the form of a vehicular crossing to the car park so that pedestrians could continue to use the footway but it would be reinforced to carry any larger vehicles which may service the development from time to time. These larger vehicles may also use the lay-by which is on the opposite side of Old Castletown Road where waiting is restricted to 90 minutes, if space is available.
- The application site is situated on the inside edge of the Central Area of Douglas and its residential areas, commercial areas and shopping areas. It is linked to these areas by continuous footways and therefore pedestrians can safely and conveniently walk between them and the proposed development.

5.4 The application is also accompanied by a Flood Risk Assessment, which recommends that the development utilises suitable flood resilient construction

techniques in order to protect the car park level. As with Quay West on the opposite side of the river the riverside wall will be tanked up to a level which helps to achieve this objective.

## 6.0 Summary

6.1 The application site is within the central area of Douglas and is at present occupied by unused workshops. Its Light Industrial zoning in the Douglas Local Plan simply reflects that previous use and planning approval in principle has been granted under PA 04/01417 to redevelop the site with apartments. It is a previously developed site in a sustainable location and must be developed efficiently in order to accord with the provisions of the Isle of Man Strategic Plan.
6.2 This application simply seeks confirmation that, in principle, the redevelopment of the site with an office scheme is acceptable. As such it does not seek approval for a building of a particular size or design, which are amongst the issues that would form the subject of a subsequent Reserved Matters application. This application does however include information which is sufficient to demonstrate that the site can be accessed safely and that a redevelopment scheme will take account of flood risk.

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*Data sourced from the Isle of Man public planning register under the [Isle of Man Open Government Licence](https://www.gov.im/about-this-site/open-government-licence/).*
*Canonical page: https://planningportal.im/a/875-braddan-bridge-works-site-replacement/documents/1150054*