**Document:** APL Plan Design and Access Statement (Part 1 of 2)
**Application:** 21/01435/B — Variation of condition 2 of PA 19/01061/B for the variation of condition 2 of PA 15/00636/A approval in principle for the erection of a dwelling, to extend the period of approval for a further 2 years
**Decision:** Permitted
**Decision Date:** 2022-03-16
**Parish:** Braddan
**Document Type:** report / design_access_statement
**Source:** https://planningportal.im/a/8330-braddan-former-howstrake-holiday-extension-new-build/documents/943739

---

# APL Plan Design and Access Statement (Part 1 of 2)

## Planning, Design and Access Statement

### Howstrake Development Project

On behalf of Allprop Ltd Project Ref: 28538 | Rev: AA | Date: June 2015 Office Address: 2nd Floor, 160 West George Street, Glasgow G2 2HG T: +44 (0)141 352 2360 E: glasgow@peterbrett.com

## Document Control Sheet

[Table omitted in markdown export]

Project Name: Howstroke Development Project
Project Ref: 28535
Report Title: Planning, Design & Access Statement
Date: June 2015

[Table omitted in markdown export]

Peter Brett Associates LLP disclaims any responsibility to the Client and others in respect of any matters outside the scope of this report. This report has been prepared with reasonable skill, care and diligence within the terms of the Contract with the Client and generally in accordance with the appropriate ACE Agreement and taking account of the manpower, resources, investigations and testing devoted to it by agreement with the Client. This report is confidential to the Client and Peter Brett Associates LLP accepts no responsibility of whatsoever nature to third parties to whom this report or any part thereof is made known. Any such party relies upon the report at their own risk.

## Contents

1 Introduction ..... 6
1.2 Taking a sensitive approach to development ..... 6
1.3 Document Structure ..... 7
2 Site Context ..... 9
2.1 The Site ..... 9
2.2 Surroundings ..... 10
2.3 Visual Context ..... 12
2.4 Planning History ..... 14
3 Consideration of Planning Policy ..... 15
3.2 Isle of Man Strategic Plan, 2007 ..... 15
3.3 Isle of Man Strategic Plan 2015 (Draft) ..... 15
3.4 Onchan Local Plan 2000 ..... 16
3.5 Landscape Guidance ..... 17
4 Development proposal ..... 19
4.2 Siting Parameters ..... 19
4.3 Principles of Height, Scale and Massing ..... 19
Principles of ..... 21
4.4 Design ..... 21
4.5 Illustrative Proposals ..... 24
5 Access ..... 25
5.2 Key Policy Documents ..... 25
5.3 Current Site Access ..... 25
5.4 Proposed New Access ..... 25
5.5 Traffic Generation ..... 25
6 Drainage, Water Supply \& Utilities ..... 26
6.2 Electricity ..... 26
6.3 Water ..... 26
6.4 Foul Water Drainage ..... 26
6.5 Surface Water Drainage ..... 26
6.6 Telecommunications ..... 26
6.7 Gas ..... 26
6.8 Conclusion ..... 26
7 Ecology ..... 27
7.2 Habitat ..... 27
7.3 Protected Species of plants ..... 27
7.4 Protected species of animals ..... 27
7.5 Summary ..... 27
8 Conclusions ..... 28

Planning Statement
Howstrake Development Project
Figures
Figure 2.1 - PBA photographs of the site, 2014 ..... 9
Figure2.2 - Groudle Cottages and the view towards Howstrake, PBA 2014 ..... 11
Figure 2.3 - Viewpoint location plan ..... 12
Figure 2.4 - View from Sea Lion Rocks Tea Room and Visitor Centre ..... 12
Figure 2.5 - View from Groudle Railway ..... 12
Figure 2.6 - View from Ballamenagh Road ..... 13
Figure 2.7 - View from Ballamenagh Road ..... 13
Figure 4.1 - Viewpoint location plan ..... 18
Figure 4.1 - Viewpoint location plan ..... 18
Figure 5.1 - Howstrake holiday camp. Previous development on site. Photo taken by
www.oldukphotos.com ..... 20
Figure 5.2 - Existing development - view from the Groudle Railway line ..... 20
Figure 5.3 - The Brow of the Hill: Southern House. Photo by Michael Nicholson ..... 22
Figure 5.4: Stormy Castle. Photo by Charles Hosea ..... 23
Figure 5.5 - House Boz. Photo by Barend Roberts \& David Ross ..... 23
Figure 5.6 - Indicative section through the proposed development showing possible development
configuration ..... 24
Figure 5.7 - Illustrative view of the proposed development site showing possible development
configuration ..... 24
Tables
Table 3.1 - Landscape Considerations as described in Draft PPS 2/09 ..... 17

## 1 Introduction

1.1.1 Howstrake, home of the first holiday camp in the British Isles, has lain vacant since its last visitors left in 1973. The c. 11 ha of land within our client's ownership is located on the coast south of Groudle Glen, and adjacent to King Edward Road and the Manx Electric Railway. The site area is 3.6 ha . While there has been some natural re-vegetation (mainly of gorse), the main accommodation blocks, other buildings, former swimming pools, stairways and path networks remain prominent but derelict and in a poor state of repair. The site does not have public access and there are no rights of way on the site. The remaining buildings on site are heavily vandalised.
1.1.2 Without investment to tackle the condition of the site and access to it, Howstrake will deteriorate further, continuing to blight the landscape while making no positive contribution to the Isle of Man economy. However, development of some kind will be required to generate the value needed to realise site improvement.
1.1.3 Despite various redevelopment proposals since Howstrake's closure none have been taken forward (see para 2.1.1). Previous proposals have generally failed to recognise the site's sensitive relationship to surrounding areas, focussing more on its capacity to accommodate relatively high density residential or holiday accommodation. The most recent application, submitted in 2009, also lacked any detailed information showing how the site would be accessed and how utilities would be provided.
1.1.4 The present owner now wishes to bring the site back into use and a different approach has been adopted. This statement is informed by a review of existing policy, the site history, site visits and technical assessments; and initial discussions with various bodies including Manx National Heritage and the Department of Infrastructure.
1.1.5 The rationale for development at Howstrake is straightforward: turning a derelict and unused site which detracts from the Isle of Man's appeal into an asset which can make a positive contribution to, landscape and other objectives.

#### 1.2 Taking a sensitive approach to development

1.2.1 Recognising Howstrake's sensitivity, the site's landscape and natural heritage features and its relationship with nearby settlements have been taken into account before considering where and what scale of development might be brought forward.
1.2.2 Preparation of this application has involved a combination of comprehensive site analysis and consideration of technical challenges with a series of focussed and appropriate consultations. It has included:

- Consultations with:
- Chris Balmer, Planning officer with the Department of Environment, Food \& Agriculture;
- Officers from the Highways Service, Department of Infrastructure;
- Meetings also took place with Manx National Heritage.
- An ecological survey of the site as detailed in the accompanying report titled "Results of an Ecological Survey of land at Howstrake Camp site, Onchan, Isle of Man, May 2015" prepared by the Manx Wildlife Trust;
- An assessment of the available utility connections and drainage infrastructure as detailed in the accompanying report titled "Utilities Infrastructure Technical Report", April 2015 prepared by Peter Brett Associates;

## Planning Statement

### Howstrake Development Project

- A review of the access options for the site as detailed in the accompanying report titled "Transport Considerations", June 2015 prepared by Peter Brett Associates;
- A review of the road safety implications of the proposed revised access arrangement for the site, as detailed in the accompanying report titled "Road Safety Opinion", June 2015 prepared by Peter Brett Associates;

#### 1.2.3
On the basis of the discussions shown above, the following core principles for improving the site were identified including:

- Critically, a desire for any development to be of a design, scale and density which clearly respects its sensitive landscape setting;
- Protection of key coastal views and landscape characteristics; and
- Development of a sufficient value to generate the funds required to redevelop the site, remove the existing structures and improve the landscaping and overall appearance of the site.

#### 1.2.4
Initial analysis indicated that development embracing these principles would be deliverable and viable.

### 1.3 Document Structure

#### 1.3.1
The following sections of this Planning, design and access statement are structured as follows:

- **Chapter 2** - Site context including description of the site and its surroundings, the important visual context and the recent planning history;
- **Chapter 3** - consideration of planning policy and the important policy considerations which have shaped this proposal;
- **Chapter 4** - a description of the proposal and the design parameters which will govern the architecture of a subsequent detailed application for planning permission. This chapter also includes commentary on relevant design influences and a consideration of the possible building configuration that can be expected to result from application of these parameters;
- **Chapter 5** - a summary of the proposed access arrangements - to be read in conjunction with the accompanying road safety opinion and statement of transport considerations;
- **Chapter 6** - A summary of the proposed site drainage, water supply and utilities connections;
- **Chapter 7** - A summary of the ecology of the site and any constraints imposed by that;
- **Chapter 8** - Summary conclusions.

#### 1.3.2
The planning application is supported by the following drawings, and also by the various reports detailed in paragraph 1.2.2 above.

- Drawing No. 28538-01 - Site location plan Extent of planning application area and existing topographic survey
- Drawing No. 28538-02 - Site Development Parameters
- Drawing No 28538-03 - Existing Tree Cover

- Drawing No. 28538-04 – Illustrative Site Development Diagram

## 2 Site Context

![A composite image displaying four photographs of a derelict coastal site, featuring interior shots of a graffiti-covered, debris-filled room and exterior views of the sea and a parked car.](https://images.planningportal.im/2021/11/113662.jpg)

#### 2.1 The Site

2.1.1 The former Howstrake Holiday Camp site is identified in the Onchan Local Plan 2000, the current Local Plan, as being in a "state of dereliction" and "in dire need of restoration". It notes that the site can be clearly seen from both King Edward Road and the southern end of Ballameanagh Road. The site is described as being on "an exposed and prominent coastal site".
2.1.2 The site is steep but layered with a legacy of platforms and access ways that lend themselves to natural appreciation of the views and wider links.
2.1.3 Measures have been taken to prevent general public access to the site. Nevertheless, the site continues to be regularly entered and used by members of the public, resulting in the accelerated deterioration of the buildings and other detrimental impacts on the amenity of the site.

Figure 2.1 - PBA photographs of the site, 2014

2.1.4 The site is occupied by deteriorating, highly visible permanent structures which have not blended into the landscape. The buildings, former swimming pool and other features (including stairways) have been redundant since 1973. All are in poor condition and are visible from the pavement and railway line on King Edward Road.
2.1.5 The nearest Rights of Way are the Baldromma to Groudle path (ref 186A), and Groudle to Beach (Ref 429), both located to the north of the site.

## 2.2 Surroundings

2.2.1 Groudle Glen lies immediately to the north of Howstrake. Following planning permissions in 1994 and 1992, a combination of holiday chalets, studio apartments - 38 units in total - were developed at Groudle Glen. Eleven of the units subsequently received approval for conversion to residential use.
2.2.2 The area to the south of the site is steep cliff and there are no neighbours. The nearest neighbours to the south are approximately 600 m away from the tram stop at the existing entrance to the site. To the west of the site is King Edward Road, the railway line and King Edward Bay Golf Club. The steep slope down from the golf course to the site means that the site is not visible from the course.

![A composite image showing a dilapidated, single-story concrete building on a coastal cliff, including close-ups of the ruined structure and a wide view of the site overlooking the sea.](https://images.planningportal.im/2021/11/113663.jpg)

## Planning Statement

![A composite image containing three photographs showing a row of white houses on a hillside, a stream in a wooded area, and a river mouth on a beach.](https://images.planningportal.im/2021/11/113665.jpg)

### Howstrake Development Project

**Figure 2.2 – Groudie Cottages and the view towards Howstrake, PBA 2014**

## 2.3 Visual Context

![A photograph labeled 'View 1' showing a coastal building with a veranda and picnic tables overlooking the sea and a headland.](https://images.planningportal.im/2021/11/113667.jpg)

2.3.1 The Onchan Local Plan (2000) notes that the Howstrake site "remains unimproved and visually intrusive". The former holiday camp buildings which are heavily vandalised remain visible from King Edward Road. The following series of view points have been selected following careful consideration of the visual envelope of the site. The topography of the coastline is such that vantage points are restricted to views from the North East, as illustrated in figure 4.1.

Figure 2.3 - Viewpoint location plan
2.3.2 View 1 is taken from the Sea Lion Rocks Tea Room and Visitor Centre looking back towards the Howstrake site. This is a key coastal view. The side of the existing holiday block building is visible from this viewpoint although the steep slope from Groudle Glen up to the site means that it is not possible to view any other structures on the site.
2.3.3 View 2 is taken from the end of Groudle Railway towards the Howstrake site.
2.3.4 Views 3 and 4 are taken from different points on Ballamenagh Road looking towards Groudle Cottages and the Howstrake site. The Groudle Cottages are the main feature in this view and the development on the Howstrake site is predominantly hidden by the steep slope and vegetation.

Figure 2.4 - View from Sea Lion Rocks Tea Room and Visitor Centre

Figure 2.5 - View from Groudle Railway

View 2

Figure 2.6 - View from Ballamenagh Road

View 3

Figure 2.7 - View from Ballamenagh Road

2.3.5 The above series of views shows the sensitivity of this coastal location and demonstrates the requirement for carefully considered development and landscape. The site is visible from public vantage points to the North East and requires sensitive treatment in order to preserve the integrity of these views.
2.3.6 In the context of General Policy 3, discussed in section 3.2 below, the proposals will substantially enhance these views by removing the redundant, unsightly remnants of the Howstrake Holiday Camp and complying with the specific exemption provided in the Strategic Plan for the construction of buildings outside the zoned areas.

![photograph from page 12](https://images.planningportal.im/2021/11/113669.jpg)

![photograph from page 12](https://images.planningportal.im/2021/11/113670.jpg)

## Planning Statement

### Howstrake Development Project

#### 2.4 Planning History

##### 2.4.1
There have been a series of planning applications on the Howstrake site since 1986 with the most recent in 2009:

- **86/00317/A:** Approval in principle to develop:
  - a) Part of site for residential use and
  - b) Part of site for tourist use, Howstrake Holiday Camp, King Edward Rd, Onchan. Howstrake Holiday Camp, King Edward Rd, Onchan. Refused

- **87/00637/A:** Approval in principle to develop the end of land to form 12 residential plots and 25 self-contained tourist chalets, Howstrake Holiday Camp, Onchan. Plots and 25 self-contained tourist chalets, Howstrake Holiday Camp, Onchan. Refused on Review.

- **88/04256/A:** Approval in principle to:
  - 150-bedroomed hotel/conference/health facilities and
  - 200 residential units, Howstrake Holiday Camp Site, Onchan. Howstrake Holiday Camp Site, Onchan. Permitted

- **94/00816/B:** Erection of hotel with associated parking, Howstrake Holiday Park Site, Onchan. Former Howstrake Holiday Camp King Edward Road, Onchan. Isle Of Man IM3 2JP. Refused

- **94/00817/A:** Approval in principle for the erection of 200 dwellings, Howstrake Holiday Park Site, Onchan. Former Howstrake Holiday Camp King Edward Road, Onchan. Isle Of Man IM3 2JP. Refused.

- **09/01041A:** Approval in principle for the erection of a detached dwelling, Former Howstrake Holiday Camp King Edward Road, Onchan. Isle Of Man IM3 2JP. Refused. Appeal was lodged and subsequently withdrawn.

##### 2.4.2
With the exception of the most recent application which we understand did not have sufficient supporting information, previous applications have sought high density development of a scale considered inappropriate to this location. The current proposals have been designed to respond these concerns and permission is now sought for a single dwelling and relevant supporting studies are included to provide the Department with the required information.

## 3 Consideration of Planning Policy

3.1.1 This chapter examines existing planning policy and guidance pertinent to the development of this site. It summaries the policy framework within which the application will be determined and demonstrates that the development is compliant and can be positively considered by the Department.

#### 3.2 Isle of Man Strategic Plan, 2007

3.2.1 The Isle of Man Strategic Plan was produced by the Department of Local Government and the Environment in 2007 to guide development. While strategic in nature, several of its spatial policies are relevant to Howstrake. Most notably, as Howstrake is previously developed land, General Policy 3 offers clear opportunity for the future;

### General Policy 3

Development will not be permitted outside of those areas which are zoned for development on the appropriate Area Plan with the exception of:
(c) previously developed land which contains a significant amount of building; where the continued use is redundant; where redevelopment would reduce the impact of the current situation on the landscape or the wider environment; and where the development proposed would result in improvements to the landscape or wider environment;
3.2.2 The proposed development of Howstrake is clearly compliant with the above policy:

- It is previously developed land, comprising the remnants of Howstrake Holiday Camp. Previously Developed Land is defined in the Strategic Plan (Appendix 1) as: "that which is or was occupied by a permanent structure, including the curtilage of the developed land and any associated fixed surface infrastructure."
- It contains a significant amount of building. The remains of the chalet buildings and swimming pool structures are evident, and the hardstanding associated with the wider site is still intact;
- The continued use is redundant. The last visitors left in 1973 and the site has been vacant since;
- As shown in the images in Chapter 2, it is derelict and visually intrusive in its current condition. Redevelopment will significantly reduce the impact of the current situation on the landscape and the wider environment;
- The proposals, governed by the design parameters set out in this document will result in a significant improvement to the landscape and the wider environment.
3.2.3 In this context, the development proposals can be positively considered by the Department. They will deliver significant gain in landscape and visual terms and will secure a positive future for this long neglected part of the Island.

#### 3.3 Isle of Man Strategic Plan 2015 (Draft)

3.3.1 We note that a new version of the Isle of Man Strategic Plan is now available in draft form and is scheduled for adoption later in 2015. We have considered the content of the Draft and note that it does not make any material changes to the policies of the 2007 Strategic Plan that would affect this planning application. Importantly the text of general Policy 3 as quoted above remains unchanged in the Draft. It is further noted that until the review of the Isle of Man Strategic Plan 2015 is complete the Isle of Man Strategic Plan 2007 remains in force.

---

*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/8330-braddan-former-howstrake-holiday-extension-new-build/documents/943739*
