**Document:** APL Planning Statement
**Application:** 21/00527/B — Creation of a controlled parking area for motorhomes
**Decision:** Permitted
**Decision Date:** 2021-07-27
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/7532-braddan-the-boneyard-hard/documents/933122

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# APL Planning Statement

## Planning Statement Use of the “Boneyard” in Noble’s Park as a Motorhome Aire.

![This image displays a site plan titled 'Noble's Park – Assessment of Park Amenity Value' featuring color-coded zones with numerical ratings overlaid on the park grounds and adjacent residential streets.](https://images.planningportal.im/2021/05/6827047.jpg)

### Zoning and Use

The “Boneyard” area of Noble’s Park is situated with the BMX track and dog walking area to the southeast and the TT showerblock to the north west. The area is zoned in the Area Plan for the East as Open Space - Park. During the periods when the park is occupied for motorsport events the “Boneyard” is used for the parking of motorhomes and camping by competitors and their teams. An infrastructure of electricity supply points has been installed over the years to support this use during motorsport events. There is also a shower and toilet block located adjacently for use by those camping during the festivals.

Outside the motorsport festival periods, the area cannot easily be used for any other purpose because of the infrastructure required during the festival periods. For many years the Council has issued permits to motorhome users permitting them to park motorhomes under certain conditions including a maximum stay of 4 consecutive nights or 14 days in any quarter. However, until the making of the Noble’s Park Off-Street Parking Places Order 2021 in January 2021, the Council had no enforcement powers available. Since the making of the Order, the Council is now enforcing a prohibition of motorhome parking in Noble’s Park as a measure to tackle the problem of motorhome owners storing their vehicles permanently within the park.

### Assessment of Amenity Value

The Council has undertaken an assessment of the leisure amenity value of the whole of Noble’s Park and, as a result of the “Boneyard” area’s use during TT, it has been assessed as having little or no leisure amenity value to the public.

Figure 1 – Assessment of Park Leisure Amenity Value. The “Boneyard” area has been assessed by Council officers as currently having no amenity value to park users.

### Traffic Management Problems

![photograph from page 2](https://images.planningportal.im/2021/05/6827048.jpg)

![photograph from page 2](https://images.planningportal.im/2021/05/6827049.jpg)

![photograph from page 2](https://images.planningportal.im/2021/05/6827050.jpg)

Over recent years the Council has faced several problems including the parking and storing or heavy goods vehicles and large trailers, motorhomes and other irregularly used vehicles within Noble’s Park. This has caused problems in the lead up to TT and FOM when the vehicles hamper the set-up of facilities for the festivals. It also causes problems as a result of higher levels of traffic through the park than are desirable and the impact on the overall leisure amenity of Noble’s Park as a result of inappropriate and unsightly vehicles. With specific regard to the storage of motorhomes, when the vehicles are left for long periods they become dirty and weather-stained and detritus can build up around them unlike the same types of vehicles being actively used for leisure purposes.

Motorhomes, caravans and trailers stored in Noble’s Park without the Council’s permission prior to the making of the Noble’s Park Off-Street Parking Places Order 2021.

### Noble’s Park Traffic Management Plan

In 2018 Douglas Borough Council drafted a Traffic Management Plan with the aim of reducing unnecessary traffic through the park and improving the overall management of vehicle parking within the park. Working with the Department of Infrastructure the Council drafted and subsequently made the Noble’s Park Off-Street Parking Places Order 2021 to provide enforcement powers against unauthorised or inappropriate vehicular use of the park. Traffic Regulation Orders have also been prepared to reduce through traffic and provide enforcement powers to the Department of Infrastructure on the roadways through the park.

### Motorhomes

In preparing the Noble’s Park Traffic Management Plan, consideration was given to prohibiting motorhomes from using the park outside the motorsport festivals. This would have reversed a practice that has been in operation for many years. It was recognized however that the problem was the lack of enforcement powers that was leading to the mass storage of these vehicles in the park and that a tighter enforcement framework could tackle the problem without penalising those motorhome users who comply with the conditions of use.

It was also recognised that the provision of official motorhome overnight parking has some potential benefits. Most motorhomes are completely self-contained and consequently their users are not physically constrained by the need for the facilities provided by full campsites. As a result motorhomes are able to be used anywhere they are permitted and this is part of their attraction. The only facilities required are a flat location to park and the occasional need to empty a chemical toilet and ‘grey’ water and to top up the tanks with fresh water. An electricity supply, toilets and showers, although not required are considered a bonus. Many towns, particularly in mainland Europe provide facilities called Aires or Stellplatz of just this nature where motorhomes are invited to park either free of charge or for a tariff typically much lower than a fully equipped campsite. The main differences between a Stellplatz and a campsite are;

-  Users can arrive or depart at any time, even at night.

-  There is no reception where one has to register or deregister.

-  Sanitary facilities are not available, or at least only to a limited extent.

-  The erection of tents, including awnings, is not permitted.

-  The stay is limited to a few nights, seasonal or permanent camping is not permitted.

-  Lower accommodation prices, sometimes free of charge.

-  In the case of chargeable spaces, the fee is usually paid at a parking ticket machine or an honesty box.

See https://de.wikipedia.org/wiki/Reisemobil-Stellplatz . The town authorities provide the Aires/Stellplatz in recognition that motorhome owners will spend money in the local economy and that although they are not paying for accommodation, they will buy food, supplies, fuel and visit local bars and restaurants. Furthermore, the “Boneyard” area is located adjacent to the newly refurbished BMX track and offers the potential for BMX riders and their families to visit in motorhomes and stay right next to the facility. The Visit Isle of Man website lists fourteen campsites suitable for motorhomes. None of these are located in Douglas, the nearest being Glen Dhoo Campsite and Lower Ballacottier Campsite both in Onchan. Glen Dhoo Campsite is over three miles from the centre of Douglas and is only open during the motorcycling festivals and Lower Ballacottier Campsite is four miles from the centre of Douglas and a twenty to thirty minute walk from the nearest bus stop. Neither of these campsites are

suitable for tourists or other Manx motorhome owners wishing to stay within walking distance of the centre if visiting Douglas’s pubs, bars or restaurants.

Motorhomes are generally over 5 metres in length and considerably higher than normal vehicles. As a consequence they do not fit in multistorey car parks and cannot be parked in standard 4.8 metre long parking bays. All off-street car parks in Douglas town centre have marked bays and so it is an offence for motorhomes to use them if they overhang the bay. Consequently the only place for visiting motorhomes to park is on street. The provision of the aire in Noble’s Park would provide a suitable location for visiting motorhomes to be parked whilst their occupants are visiting the shops and services in Douglas town centre. The Visit Isle of Man website actively encourages people to bring their motorhomes to the island and it is reasonable to expect visiting motorhomers to want to visit the Manx Museum, shops, the Steam railway and the electric railway but currently there are no off-street parking places for them to park their vehicles in the capital. Noble’s park is a 15 minute walk from the Promenade and is within very easy cycling distance which will be improved further once the proposed active travel infrastructure is delivered.

A Stellplatz in Niemayer – Mardorf, Germany.

### Enforcement

The Noble’s Park Off-Street Parking Places Order 2021 currently prohibits motorhomes from parking in Noble’s Park. If planning consent is granted, the Council would amend the Order to permit the parking of Motorhomes in the Aire in the Boneyard. Users would be required to purchase a pay & display ticket that would entitle them to park their motorhome for 24 hours. Council officers will then be able to determine whether vehicles are being used actively for leisure or tourism and issue Additional Parking Charges to any which are not displaying a valid ticket. It is anticipated that this regime would result in those motorhomes that are present in the park being used by tourists or leisure visitors during a visit to Douglas or Noble’s Park rather than for storage.

### Summary

The proposed motorhome aire in Noble’s Park aims to provide a facility for tourists and visitors to Douglas to park their motorhome on a pay per night basis and to eliminate the use of the park for the long term storage of vehicles.

![photograph from page 4](https://images.planningportal.im/2021/05/6827051.jpg)

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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/7532-braddan-the-boneyard-hard/documents/933122*
