**Document:** Planning Statement
**Application:** 08/01418/A — Approval in principle for the development of the site for residential and retail / commercial purposes
**Decision:** Refused
**Decision Date:** 2009-01-19
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/85882-braddan-former-gas-production/documents/1590513

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# Planning Statement

## Planning Statement

### In respect of

### Application for Approval in Principle

### for the mixed use development of part of the Manx Gas site

### South Quay, Douglas

Document no ad01

June 2008

JUNE08
ad01

## Contents

1. Introduction
2. Site description
3. Local and Strategic Plans
4. Outline proposals
5. Traffic report
6. Acoustic report
7. Wildlife report
8. Conclusion

1.1 Manx Gas own the application site and wish to obtain Planning Permission for the development of a scheme of residential accommodation with retail/commercial at South Quay level along with associated car parking.

2 Site Description
2.1 The site is currently used for the storage of empty gas tanks and cylinders (photo 1) and was previously the location of the Douglas area main LPG/air gas production plant, associated equipment and Town Gas holder. The last remnant of which is the concrete base of the holder. (photo 2)

Photo 1

Photo 2

![A photograph showing an outdoor fuel storage area with rows of yellow jerry cans and large white cylindrical tanks.](https://images.planningportal.im/2008/07/471378.jpg)

![A photograph showing a gravel site with industrial vehicles and equipment in front of a steep, rocky cliff face covered in vegetation.](https://images.planningportal.im/2008/07/471379.jpg)

2.2 The site covers some $8815 \mathrm{~m}^{2}$ in plan area the main portion of which sits at an elevated location overlooking the inner harbour. (drawing ap00).
2.3 Vehicular and pedestrian access to the site is gained from South Quay (photo 3) and from the adjacent light industrial site.

Photo 3
2.4 The site is bounded to the south and south west by the faces of the former quarry. These rise on the south boundary to some 45 m above the level of the elevated portion of the site, reducing to some 16 m on the south west boundary. (photos $4 \& 5$ ).

Photo 4

![A street-level photograph showing a white building with gabled ends, likely garages, next to a larger white building with a red car parked nearby.](https://images.planningportal.im/2008/07/471380.jpg)

![A grainy photograph showing a steep, rocky hillside or cliff face with vegetation along the ridge line, dated April 2008.](https://images.planningportal.im/2008/07/471381.jpg)

Photo 5
2.5 The site includes one building which occupies a location on South Quay and is currently used as a store by Manx Gas.
2.6 As is to be expected of a site previously used for the production and handling of LPG/Air and the storage of Town Gas, the ground is contaminated. A survey has been carried out and the extent and degree of contamination has been determined. Manx Gas has undertaken some initial decontamination works.

## 3 Local and Strategic Plans

3.1 The Isle of Man Strategic Plan 2007 includes the following relevant policies -

Strategic Policy 1 -'Development should make the best use of resources by: optimising the use of previously developed land', 'being located so as to utilise existing and planned infrastructure'
3.2 This site is previously developed land and is located close to existing infrastructure and services.
3.3 Strategic Policy 7 - 'undeveloped land which is zoned in Local or Area Plans for industrial, office, or retail purposes will be retained and protected for such uses, except where those uses would be inappropriate or incompatible with adjoining uses.'
The character of the general area is being changed to that of a predominantly residential and leisure nature.

![A grainy photograph showing a dense line of trees and foliage on a slope against a bright sky, with a date stamp in the corner.](https://images.planningportal.im/2008/07/471382.jpg)

Strategic Policy 10 - 'new development should be located and designed such as to promote a more integrated transport network with the aim to: minimise journeys, especially by car; make best use of public transport; not adversely affect highway safety for all users, and encourage pedestrian movement' The proximity of the site to the town's commercial and office core would have the potential to reduce car journeys and encourage pedestrian movement if residential development were to be permitted.

Strategic Policy 11 - 'the housing needs of the Island will be met by making provision for sufficient development opportunities to enable 6000 additional dwellings. $\qquad$ to be built over the Plan period 2001to2016'.

It is conceded in the Strategic Plan that although there is sufficient land zoned for such volume of development not all of the land is capable of being developed within this timescale.

Douglas Local Plan 1998
The site is contained within an area which is currently defined as 'Light Industrial' on Map no2 of the Local Plan.

This area extends along South Quay from beyond Douglas Bridge in the west to the junction with Douglas Head Road in the east.

Policy D/HR/P2 states that -
'Industrial activities located on the South Quay should be encouraged to relocate, this however does not relate to those activities which are harbour or water based'

The site in question is wholly located within this 'light industrial' area and bounds South Quay. The current use is not related to harbour or water based activities. Indeed the majority of the uses in the designated area are unrelated to such activities.

Manx Gas is considering the strategic relocation of its operation.

3.10 It is clear that since the publication of the Local Plan further residential development in the harbour area has commenced or been approved.
3.11 In addition, the projected works to partially pedestrianise the North Quay, improve the inner harbour for leisure craft purposes and provision of a new bridge over the mouth of the inner harbour have all been implemented. These works have drastically altered the nature of the wider inner harbour area, lending the area a more defined leisure/residential character.

## 4 Outline proposals

4.1 Consideration of the potential uses which could occupy the site have led to the following conclusions -
4.2 A - Light industrial - Policy D/HR/P2 states that current light industry activities on this site should be encouraged to relocate. Manx Gas is considering the strategic relocation of its operation. We are unaware of demand for harbour or water related light industrial accommodation in the area.
4.3 B - Long term parking - Policy D/CP/2 states that -
'Long term parking for office workers will be based on peripheral surface or multi level car parks in close proximity to the main arterial roads and must provide secure car parking allied to an efficient and regular public transport system'.

This site may be regarded as being both peripheral and in close proximity to a main arterial road - South Quay.
4.4 C - Residential - although the site is not zoned for residential development in the 1998 Douglas Local Plan the developing character of the surrounding area and the desire to have light industry relocate leads one to consider that a predominantly residential use would be appropriate.
4.5 Although this application is for Approval in Principle it is considered appropriate that certain fundamental design parameters are explored and addressed in determining an overall design concept for the development of the site -
4.6 The principal issues are -
4.7 Development area - investigations into the effect that the quarry faces have on sunlight penetration into the site determines that the southerly portion of the site adjacent to the cliffs is unsuitable for residential development.

4.8 The further from the cliff face development takes place the more acceptable residential development becomes in relation to light, consequently any perceived danger from minor rockfall reduces as one moves away from the face.
4.9 The existing building fronting South Quay should be replaced with new development in order to maintain a largely unbroken street frontage. The provision of residential accommodation in this location is not felt to be appropriate and the provision of office or commercial floor space is considered to be suitable.
4.10 This street frontage development would of course be available for harbour or water based uses.
4.11 Aspect - development to the north of the existing gas holder base will be able to take advantage of good views to the east north east to the outer harbour, north over the inner harbour to North Quay and the town beyond and north west towards the Nunnery. The elevated nature of the site assists with the maximisation of views from the site. (photos $6.7 \& 8$ )

Photo 6

![A grainy photograph showing a waterfront or harbor area with various buildings, a crane, and parked vehicles or boats in the foreground.](https://images.planningportal.im/2008/07/471383.jpg)

Photo 7

Photo 8
4.12 Density - the density of the site will be affected by the aforementioned limitations on developable area, the maximum height of development envisaged, the balance between parking and apartment numbers and considerations of the effect that the existing morphology of the area may have on the layout.
4.13 Massing - consideration of the existing morphology of the surrounding area and views into the site from North Quay leads to the view that development on the plateau should be of a visually fragmented nature in order to minimise any negative visual impact.

![A grainy photograph showing a harbor or marina with boats in the foreground and a row of multi-story buildings along the waterfront in the background under a cloudy sky.](https://images.planningportal.im/2008/07/471384.jpg)

![A photograph showing an elevated view of a town with multi-story commercial buildings, a parking area, and an overcast sky.](https://images.planningportal.im/2008/07/471385.jpg)

4.14 Height - it is considered that, given the strong visual presence of the cliff, any development should not project above the skyline when viewed from North Quay. This is graphically represented on drawing as01.
4.15 Parking - the topography and underlying geology of the site determine that the incorporation of underground parking is not a viable option, equally the construction of a parking deck upon which apartments would be constructed would serve only to push the development above the skyline.
Given the aforementioned view that built development should be kept to an area to the north of the base of the former gas holder, it is considered that this area would be suitable for the location of 'at grade' car parking.
4.16 Access - the site is bounded to the north by the public highway South Quay, and it is from this roadway that vehicular and pedestrian access will be gained. An existing vehicular access is located to the eastern extremity of the boundary with South Quay. The raised plateau nature of the main part of the site determines that the internal access road will be at a maximum gradient of 1 in 10 as it rises from a point 5 metres inside the site up to the 'development platform'. Pedestrian access will also be available from this point. Whereas this 'driveway approach' to the development platform will comply with 6.18 of Part M of the Building Regulations it is considered that a stepped approach should also be provided as described in $6.16-6.17$. It is proposed that this be achieved by the provision of a stair facility as indicated on drawing ap01a. Disabled parking would be provided at development platform level on the basis of $6 \%$ of the total parking provision.

Disabled parking provision for retail/commercial accommodation on South Quay will be provided within the site and access to the building will be gained by the provision of a lift from the higher site level down to the main entrance level.
4.17 Sustainability - the reuse of previously undeveloped land together with the site's proximity to the town's commercial and office core brings a high level of sustainability to the residential development of the site. Secure provision for cycle parking should be provided.
4.18 Development diagram

Consideration of the foregoing issues has led to the production of the attached Development Diagram. This diagram shows the extent of the potential elevated development plateau, the location of parking, South Quay frontage development, access

roadway and stair/lift provision and a potential disposition of built elements taking cognisance of the issues noted above.

The diagram is based on the provision of 54 residential units and associated parking on the elevated development plateau and upper two floors of development on the frontage with South Quay, the ground floor of which would be developed for retail/commercial use.

### Traffic report

JMP Associates were appointed to prepare a Traffic Assessment in relation to the potential redevelopment of the site for primarily residential purposes.

This study was conducted to standards required by and agreed with the Department of Transport. The study concludes that the traffic generated by the projected use will not adversely affect the surrounding highways. The provision of cycle parking spaces is recommended. The full report is appended.

### Acoustic report

In order to demonstrate that a proposal for residential development in this location would not prejudiced by noise related issues, Acoustic Design Consultants were appointed to undertake a noise survey and provide proposals to ameliorate the situation if appropriate.

Noise readings were taken and the results used to place the site within a framework of nationally accepted criteria. The outcome of the study suggests that there is a need for the implementation of basic sound attenuation measures in the construction of residential units within certain distances from South Quay.

The full report is appended.

### Wildlife report

In recognition of the potential for the cliff face and base to provide habitats for flora and fauna Manx Wildlife Trust were appointed to carry out surveys to establish if there are issues in this regard which could affect development of the site.

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The study determined that in relation to lizards '....from the data recorded and the suitability of the site for lizards, it is concluded that there is a high probability that lizards are NOT present on the site.'

In relation to gulls, although 'there is a very active herring gull colony on the north facing cliffs, only 4 birds were observed as potentially sitting on nests in the area of site under consideration'. '...it is not considered to be a significant herring gull nesting area'.

The full report is appended.

## Conclusion

- The site is currently designated for Light Industrial use.
- Policy D/HR/P2 states that -
'Industrial activities located on the South Quay should be encouraged to relocate, this however does not relate to those activities which are harbour or water based'
- Manx Gas is considering the strategic relocation of its operation.
- We have no evidence that there are unfulfilled 'harbour or water based' light industrial requirements for accommodation/land in this area.
- The site is brownfield and as such its redevelopment meets criteria set out in Strategic Policies 1 and 10 of the Isle of Man Strategic Plan 2007.
- The character of the general area is changing to that of being predominantly residential/leisure and it is contended that, in line with Strategic Policy 7, continued industrial use of this site is inappropriate.
- The provision of residential development will help towards the satisfaction of Strategic Policy 11.
- The site is within easy walking distance of the office/commercial core of the town which along with the reuse of a brownfield site confirms that development of this site meets requirements for sustainable development.

- With suitable remediation the site can be made safe for redevelopment in line with Environment Policy 26 of the Isle of Man Strategic Plan 2007.
- There are no traffic, acoustic or wildlife habitat reasons to suggest that residential development is not appropriate.

It is requested that, given the foregoing, appropriate consideration should be given to this application for Approval in Principle.

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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/85882-braddan-former-gas-production/documents/1590513*
