**Document:** APL Planning Statement
**Application:** 21/01537/B — Erection of tourist accommodation and marquee for the period 1st May to 30th September 2022
**Decision:** Deemed withdrawn under legislation
**Decision Date:** 2022-08-17
**Parish:** German
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/8420-german-swimming-pool-site-marine-parade-tourist-accommodation-marquee/documents/944854

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# APL Planning Statement

![A photograph showing an outdoor recreational area with a skate park and sports court situated next to a coastal road and the sea.](https://images.planningportal.im/2021/12/113986.jpg)

## P05 - Planning Statement In Support Of The Erection Of Tourist Accommodation And Marquee And Use Of The Site For Tourist Accommodation Between 1St May, 2022 And 30Th September, 2022, Former Swimming Pool, Marine Parade, Peel

December, 2021

![A photograph showing a temporary metal fence enclosing a concrete ramp or platform structure near a body of water.](https://images.planningportal.im/2021/12/113987.jpg)

### 1.0 Introduction

1.1 The site is the site of the former swimming pool located on the south eastern side of Marine Parade at the north eastern end of Peel's promenade. The site has a frontage of approximately 140m and a depth - front to back - of just under 40m.

1.2 The site currently accommodates a flat artificial grassed area at the north eastern end where there are benches and tables. Alongside this is a tarmacadamed area which currently accommodates skateboard/BMX jumps and ramps with railings separating this from the highway. Beside this are two hard surfaced tennis courts which have higher boundary fencing alongside the highway. Both the

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

tennis courts and the BMX/skateboard area back onto a grassed lane on top of a sandstone wall at the rear which provides access to the bowling green which sits alongside the tennis courts. The tennis courts currently have no nets which were removed at the end of the summer and part of the skatepark is fenced off.

1.3 Public access runs through the site (PROW 506 - Walpole Road to the Headland) and to the broogh area to the south which rises to join Peveril Terrace and Mount Morrison which sit 64m from the nearest point of the site and considerably higher.

1.4 The site is owned and managed by Peel Town Commissioners who have been consulted on this proposed use of the site for tourist accommodation and they are amenable to the site being used for an initial trial period of one year with any income generated being reinvested in the long term improvement for this area: this was agreed by the Board on 22.09.21.

1.5 Peel Town Commissioners have advised that the tennis courts are used, albeit lowly other than in Wimbledon week and they are reviewing the future of the courts with a long term intention to improve them. They stated that it is their long standing view that the site is underused and should a better tourist or leisure use be found for it, they would relocate the existing facilities to another part of the town. The Commissioners have invested heavily in the Swimming Pool and Campsite areas and have made representations to the Area Plan for the North and West to have the remaining undeveloped land adjacent to Ballaquane Road re-designated as Public Open Space to replace that which could be lost as a result of the expansion of the Peel Clothworkers' School which will support the growth of the town. They are also looking to expand the playground facilities at West View and leisure use on the Headlands Field.

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

![A composite image showing two views of a coastal site, featuring a beach promenade and a grassy slope with a retaining wall.](https://images.planningportal.im/2021/12/113990.jpg)

1.6 They advise that the skate park requires major refurbishment and one of the pieces of equipment is fenced off to prevent its use. They intend to undertake work on the skate park but what and when is done depends on alternative proposals for this site but at present the skate park is not available as work is required on it and the Commissioners are considering relocating this facilities to a less exposed location.

### 2.0 The proposal

2.1 Proposed is the installation of portable cabins on the site for use as tourist accommodation during part of 2022 (summer months - May to September inclusive). The operation would involve only the provision of a cold breakfast within the site and no other catering. No parking is understood to be provided on the site and users would rely upon available parking on Marine Parade and in the immediate vicinity.

2.2 The units will be 'dressed' with frontages which, from the front present the appearance of a group of traditional beach huts, arranged in rows and coloured differently and brightly. No changes will be made to the site and parking will be provided on street using the existing parking spaces on Marine Parade in front of and close to the site.

2.3 There will be 45 units in total, each single or twin beds and a marquee which will be 9m by 12m which will provide communal facilities for those staying on the site.

### 3.0 Planning status

#### Peel Local Plan

3.1 The site lies within an area designated on the Peel Local Plan of 1989 as Tourism:

3.2 The site lies outside of the town's Conservation Area which ends just before the bowling green. There are no Registered Buildings on the site, no trees - Registered or otherwise and the site is not at risk of flooding according to the national flood risk maps.

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

![A close-up section of a site plan or OS map showing a designated area labeled 'Tourism' with a circled number 15, surrounded by building outlines and contour lines.](https://images.planningportal.im/2021/12/113993.jpg)

![A cropped section of a site location map displaying 'Marine Parade' with green land areas and property boundaries.](https://images.planningportal.im/2021/12/113994.jpg)

## Sarah Corlett

3.3 The Written Statement accompanying the Peel Local Plan map refers specifically to this site, stating, "Part of the Marine Parade Area has already been approved for hotel use and some of the adjoining open space will be required to complete the development."
3.4 The Plan identifies the "principal open space areas" as Peel Hill, the Headlands and former bowling green, putting green and miniature golf course, the eastern coastal area bounded by Ramsey Road and the camp site on Derby Road and there is a general statement at paragraph 13.2 that open space areas within the town will generally be safeguarded from development, particularly identifying Peel Hill for such protection as well as the eastern coastal area bounded by the Ramsey Road.
3.5 Under "Tourism and Transport" it simply states: "It should be noted that an approval exists for a hotel development on the site of the swimming pool on the East of Marine Parade".
3.6 It also notes that it was anticipated at the time that tourism will become increasingly important to the economy of Peel and will exert pressure on the fabric of the town but that it is essential that the integrity of the town is retained and that any such development is sympathetic to and compatible with the overall environment of the town (paragraphs 4.11 and 4.12).

### Isle of Man Strategic Plan 2016

3.7 The starting point in the assessment of any planning application is the land use designation in the adopted local or area plan. If the development is in accordance with that designation, which this is, the Strategic Plan, General Policy 2 is applicable, stating:
"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:
(a) is in accordance with the design brief in the Area Plan where there is such a brief;
(b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them;
(c) does not affect adversely the character of the surrounding landscape or townscape;
(d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;
(e) does not affect adversely public views of the sea;
(f) incorporates where possible existing topography and landscape features, particularly trees and sod banks;
(g) does not affect adversely the amenity of local residents or the character of the locality;
(h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space;
(i) does not have an unacceptable effect on road safety or traffic flows on the local highways;
(j) can be provided with all necessary services;
(k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan;
(I) is not on contaminated land or subject to unreasonable risk of erosion or flooding;
(m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and
(n) is designed having due regard to best practice in reducing energy consumption."

## Sarah Corlett

3.8 Other policies encourage the optimal use of undeveloped and under-developed sites and the promotion of sustainable development (see Appendix One).
3.9 Whilst the site is not within a Conservation Area, it is close to it so Environment Policy 36 is applicable:

### "Environment Policy 36: Where development is proposed outside of, but close to, the boundary of a Conservation Area, this will only be permitted where it will not detrimentally affect important views into and out of the Conservation Area."

3.10 Environment Policy 43 explains that 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 reuse of sound built fabric, rather than its demolition. This echoes Strategic Policy 1 which encourages the optimisation of the use of unused and under-used land.
3.11 The Tourism Chapter explains that the Strategic Plan supports the growth of employment opportunities (Business Policy 1), and explains that some tourism facilities do not require permanent development and explains that a balance needs to be struck between the needs of tourism and the protection of the very assets which attract tourists to the Island in the first place - its unique landscape, culture and heritage. It welcomes "new forms of contemporary tourism development" (paragraph 9.5.5) and that it is more likely than the traditional Victorian hotel, that tourist accommodation demands are met through the designation of specific tourist attractions and large individual hotel sites with "new tourist accommodation incorporated into areas of mixed or residential use".
3.12 Chapter 10 of the Strategic Plan sets out the acknowledged importance and benefit of open space and leisure and recreation facilities, recommending that area plans assess the needs of the plan area in terms of sport and recreation and identify land uses in accordance with those findings. It also states:
"10.3.5 In certain circumstances it may be beneficial to allow the redevelopment of areas of underused, poorly maintained or inappropriately located open space. Development on such areas will only be permitted where alternative provision can be made. However, the new open space must be easily accessible to the local community and be at least equivalent in terms of type, quantity and quality to that which is being replaced.

Recreation Policy 2: Development which would adversely affect, or result in the loss of Open Space or a recreation facility that is or has the potential to be, of recreational or amenity value to the community will not be permitted except in the following circumstances:
(a) where alternative provision of equivalent community benefit and of equivalent or better accessibility is made available; and
(b) where there would be an overall community gain from the development,
and the particular loss of the open space or recreation facility would have no significant unacceptable effect on local open space or recreation provision or on the character or amenity of the area."

3.13 The Strategic Plan sets out standards for the provision of car parking, suggesting that in the case of hotels, motels and guest houses, one space should be provided per guest bedroom although this standard may be relaxed where development

##### "(a) would secure the re-use of a Registered Building or a building of architectural or historic interest; or

(b) would result in the preservation of a sensitive streetscape; or

(c) is otherwise of benefit to the character of a Conservation Area.

(d) is within a reasonable distance of an existing or proposed bus route and it can be demonstrated a reduced level of parking will not result in unacceptable on street parking in the locality."

(Transport Policy 7 and Appendix Seven).

##### Area Plan for the North and West

3.14 This is in preliminary stages only with a Call for Sites having been made by Cabinet Office and responses received. The plan which defines the settlement boundaries at this stage shows the site being within Peel's settlement boundary.

3.15 This document reiterates Peel's place in the settlement hierarchy as a Service Centre where development will be concentrated outside Douglas.

##### 4.0 Planning history

4.1 Planning approval was granted in principle for the development of the site for a hotel under 88/01268/A and 87/00096/A which followed an earlier application for the principle of a hotel/conference/leisure complex which was refused on appeal having been approved on review (87/01100/A).

4.2 The Marine Hall which formerly existed on the north eastern part of the site was approved for use for pilot training under 86/01277/C. Permission was granted for the principle of a multi-use civic hall and recreational community facility to replace the hall under 11/00112/A.

4.3 None of the above applications was implemented nor reserved matters applications submitted.

![A site location map showing a coastal area with a purple boundary line outlining the proposed development site near the beach.](https://images.planningportal.im/2021/12/113996.jpg)

## Sarah Corlett

4.4 The most recent application on the site which was approved on appeal was for the principle of a hotel leisure complex, residential apartments and parking spaces (05/01277/A) granted on 31.10.06. The inspector was not persuaded that there was sufficient information contained within the application to demonstrate that the development would be acceptable but the Minister determining the appeal was and the application was approved. No reserved matters application was submitted following this approval.

#### 5.0 Assessment

5.1 Prior to the submission of this application, pre-application advice was sought and provided by Jason Singleton on 29th October, 2021 where he advised:
"Initially it's good that the local authority are on board but from our perspective we have grave reservation regarding the scheme and it is not one I feel could be supported through the current planning policies.

Whilst I appreciate this concept may work at the grandstand within the enclosure of the paddock area for a short period, the same narrative on the proposed site that would be removing a degree of open space and recreational areas for the community which is not supported."
5.2 We interpret this advice as being based purely on a basic reference to Recreation Policy 2 of the Strategic Plan referred to above although without any assessment of the "amenity value to the community" of the site which is an essential element of the policy. It also fails to refer to the land use designation of the site for Tourism, not Recreation and the previous planning history of the site which accepted its redevelopment as a hotel without relocation or mitigation of the loss of the existing recreation facilities.
5.3 Notwithstanding the pre-application advice provided by the Department, the starting point of any assessment is the land use designation in the adopted development plan. In this case this is the Peel Local Plan which designates the site as for Tourism and noting the previous approvals for the development of a hotel. Indeed there has since been a further approval granted for this type of development although the Strategic Plan was not at that time, adopted so Recreation Policy 2 would not have been tested.
5.4 No planning approval has been sought or granted for the installation of the ramps and jumps on the skate/BMX park and the established use of the site is through historic use as a miniature golf facility, tennis courts, basketball court and swimming pool.
5.5 Notwithstanding the current use and historic use of the site for leisure and recreation purposes, the site is designated for Tourism and planning approval has been granted numerously since 1987 for tourist accommodation on this site. As such, the use and development of this site for tourist accommodation should be considered acceptable and supported.
5.6 Whilst the Strategic Plan through Recreation Policy 2 presumes against the loss of recreation space, it is clear that this is not universally applied and that this presumption only applies to space which "is or has the potential to be, of recreational or amenity value to the community". Therefore, if it can be demonstrated that the tennis courts, seating area and skate/BMX park are not of recreational or amenity value to the community then this policy would not effectively justify refusal of the application for the development of the site for other purposes.

5.7 Evidence of its lack of value is provided by the description of it and its future by Peel Town Commissioners (see paragraphs 1.5 and 1.6 above): it is also clear from an inspection of the site that the facilities have not been maintained and in fact some of the skate part is presently fenced off and not suitable for use:

5.8 It is also considered relevant that the owners, who are responsible for the management of most of the Public Open Space in the town, are willing to have the site used for other purposes for the proposed period.

5.9 The pre-amble to the recreation policy and the policy itself also require that the facilities to be lost should be provided elsewhere. In previous applications it was stated by the Commissioners that they would relocate the recreation facilities on the headlands should those developments have been implemented and their most recent advice talks of a site which is less exposed than Marine Parade.

5.10 It is relevant that the Commissioners' minutes state that the income generated from the use of the site as proposed would be re-invested in the area which could be seen as the mitigation of the loss of any facilities currently on the site.

5.11 The development complies with General Policy 2 - notably the design and appearance of the developed site is acceptable, there is sufficient parking and there would not be any adverse impact on those using adjacent land. The development is proposed as a temporary use of the site with the cabins being returned to UK after the Summer. Operating dates as a hotel will be 12th May to 5th September 2022 inclusive. This covers the National Rally (May 13/14), TT, Southern 100, 2-Day Trial, Classic TT/MGP, End-to-End and several other events where it is known that there is demand. The village will take approximately 7-8 days to set up and similar time to take-down and as such there would be presence on site for most of May and September.

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

![Two photographs showing the coastal site surroundings, including a grassy slope with railings and a paved area with ramps near the sea.](https://images.planningportal.im/2021/12/113998.jpg)

5.12 Whilst there were concerns raised with the most recent application for hotel development, about coastal overtopping, this was not referred to by the inspector and the site is not identified as at risk of flooding on the national maps.

#### Design and appearance

5.13 The structures will be seen from the road in front, from the rear and side where there are public footpaths and also from above so the finish of the roofs will be important. The proximity to the Conservation Area also brings a requirement for the development to sit comfortably in the streetscene and landscape. The development involves the addition of frontals to the units so that from most perspectives they appear as beach huts which are considered eminently suitable for this location. From above, from where the units will be visible, it will be clear that the units have flat roofs, not unlike the image below, although the principal vista from this perspective is not this site but the spectacular view over the bay and towards Peel Castle and the breakwater.

#### Car parking

5.14 Previous developments of this type by the applicant elsewhere on the Island experienced a variety of occupants including corporate guests who had no vehicle of their own as they flew to the Island and did not hire their own vehicle during their stay and were accommodated by sponsors' minibuses and taxis. The operator of the TT Village in 2019 found that for over 100 rooms and 160

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

![A composite image showing a coastal site with temporary tourist accommodation. The left panel shows the sea and green pitches, while the right panel displays rows of static caravans in a field.](https://images.planningportal.im/2021/12/114000.jpg)

![A photograph showing a coastal site with green rectangular areas, likely indicating the proposed location for tourist accommodation or a marquee near the sea wall and road.](https://images.planningportal.im/2021/12/114001.jpg)

## Sarah Corlett

guests the peak motorcycle count in the on-site car parks was under 20 and cars, under 10. This is perhaps not surprising given the additional cost of bringing vehicles to the Island, the number of people who fly to the Island which can be cheaper than sailing and the package can include transfers to and from the ports.
5.15 Peel Town Commissioners have advised that there are approximately 54 car parking spaces on the adjacent promenade area which are rarely used: a recent site visit revealed the following with the number of occupied spaces in brackets:

14 marked spaces directly in front of site (0)
17 spaces further up plus 3 accessible spaces ( 4 plus all 3 accessible spaces)
19 spaces in front of Marine Parade - 3 reserved (13 plus 1 parked illegally)
5 spaces at bottom of Walpole Rd (1)
7 spaces opposite Creg Malin plus bus stop (2)
Creg Malin car park - 2 accessible plus 25 (14 vehicles there on site visit)
5.16 Peel Town Commissioners have advised that the reserved spaces in front of the Marine Parade houses are for people who cannot walk long distances (more than 50 m ) and they comment that generally this area is underused for parking other than on hot weekends and when events take place. It is considered that there is adequate car parking available in the vicinity to accommodate the vehicles which may be generated by the proposal.

### Residual benefits

5.17 The site is accessible and sustainable and currently contributes little to the visual character of the area. The development will cheer up and find a use for a presently underused and neglected piece of land which is in the public gaze. The scheme will introduce additional areas of artificial grass which will improve the view from above compared with the existing hard surfacing on the skate part.
5.18 As the development will not be providing full catering, it should be self evident that the additional accommodation will support the restaurants, cafes, tourist attractions and shops in the town which should be in the application's favour.
5.19 The proposal is for a temporary use of this site for a holiday village and with no irreversible changes to the site. We do not consider that there will be any adverse impacts but the temporary nature will enable the impact to assessed and the Department will be able to see whether there are any adverse impacts without approving the development on a permanent basis. It may also be seen as a positive interim measure between the current situation if the facilities are not being used and where the Commissioners are required to spend public funds maintaining them, and when the site is ultimately developed for something on a permanent basis with the local authority gaining income during this period, income which may be invested in recreation facilities elsewhere in the town.
5.20 Due to the short term nature of the proposal and the longer term intention of the owner to use or develop it for other purposes or in a different manner, it is not feasible to introduce new planting or vegetation. As such, it is not considered possible to increase the biodiversity value of the site but there will result in no nett loss to biodiversity as a result of the proposal.

#### 6.0 Conclusion

6.1 It is considered that this temporary use will improve the appearance of the site, will result in the site being better used with a knock on effect of additional investment in the town and without any adverse impacts. The proposal is considered to accord with the land use designation on the adopted

development plan and is not inconsistent with the emerging Area Plan. The proposal is considered to satisfy or accord with General Policy 2, Strategic Policy 1, Environment Policies 36, 42 and 43, Transport Policies 4 and 7.

Sarah Corlett Town Planning Consultancy Ltd
Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW
t: 07624 485517 e: planning@sarahcorlett.com w: www.sarahcorlett.com
Directors: Sarah Elizabeth Corlett, Nicola Jane Corlett
Company Registration 134325C

## Sarah Corlett

### Appendices

### Appendix One - Strategic Plan Policies

Strategic Aim: 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.

Strategic Policy 1: Development should make the best use of resources by:
(a) optimising the use of previously developed land, redundant buildings, unused and under-used land and buildings, and reusing scarce indigenous building materials;
(b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space and amenity standards; and
(c) being located so as to utilise existing and planned infrastructure, facilities and services.

Strategic Policy 2: New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3.

Strategic Policy 3: Proposals for development must ensure that the individual character of our towns and villages is protected or enhanced by:
(a) avoiding coalescence and maintaining adequate physical separation between settlements; and
(b) having regard in the design of new development to the use of local materials and character.

Strategic Policy 4: Proposals for development must:
(a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings, Conservation Areas, buildings and structures within National Heritage Areas and sites of archaeological interest;
(b) protect or enhance the landscape quality and nature conservation value of urban as well as rural areas but especially in respect to development adjacent to Areas of Special Scientific Interest and other designations; and
(c) not cause or lead to unacceptable environmental pollution or disturbance.

Strategic Policy 5: New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases the Department will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies.

Strategic Policy 10: New development should be located and designed such as to promote a more integrated transport network with the aim to:
(a) minimise journeys, especially by private car;
(b) make best use of public transport;
(c) not adversely affect highway safety for all users, and
(d) encourage pedestrian movement

## Sarah Corlett

TOWN PLANNING CONSULTANCY

Spatial Policy 2: Outside Douglas development will be concentrated on the following Service Centres to provide regeneration and choice of location for housing, employment and services -Ramsey, Peel, Port Erin, Castletown, Onchan. Area Plans will define the development boundaries of such centres so as to provide a range of housing and employment opportunities at a scale appropriate to the settlement.

Spatial Policy 5: New development will be located within the defined settlements. Development will only be permitted in the countryside in accordance with General Policy 3.

Environment Policy 42: 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.

Environment Policy 43: 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.

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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/8420-german-swimming-pool-site-marine-parade-tourist-accommodation-marquee/documents/944854*