Highways Division Statement of Case

Highways Division

Statement of Case

PA 11/00178/B Erection of four office units with associated car parking, drainage and hard and soft landscaping works, Site Of Former Isle Of Man Holiday Camp Switzerland Road / Victoria Road Douglas

Background

1. PA 11/00178/B is an application for four office units on a vacant site on Switzerland Road in Douglas. The application is accompanied by a Transport Assessment (TA) ref 5741/001/03 dated February 2011 prepared by Sanderson Associates. This statement of case primarily refers to this document.

1. PAs 09/01976 and 09/01977 are applications by the same applicant on a larger site that the current application is part of. PA 09/01977 is for 4 office units and associated car parking on the same site as the current application. PA 09/01976 is for 5 office units and associated car parking on the adjacent site part of which is being utilised for the overflow car park included in the current application.

1. The Division's comments on these applications are attached at appendix A and give the applicant clear and detailed guidance on the requirements for a Transport Statement or Assessment. The applications were recommended for refusal. Both applications were withdrawn.

1. The main areas of concern for the Division are:

a. The impact of traffic generated by the application on the surrounding road network in terms of both traffic flow and safety b. The car parking provision to be provided c. The ability to service the site

Traffic Generation

1. The TA has assessed the traffic to be generated by the development using the TRICS database. A more robust assessment could have been made by surveying the traffic generated by the adjacent light industrial developments as recommended in appendix A, however the assessment used is acceptable and the TA has demonstrated that the traffic generated by the development will not adversely impact the existing highway network in either capacity or safety terms.

Visibility

1. The TA correctly identifies that all the vehicular traffic will access the site using the Victoria Road / Switzerland Road junction. Para 3.6 describes Switzerland Road as linking the Promenade and King Edward Road with Victoria Road but does not clarify that this is not a vehicular route. There are bollards on Switzerland Road that permit the passage of pedestrians, cyclists and motorcyclists only. This link is very steep and is likely to have a low frequency of use by pedestrians to access the bus stops on the Promenade.

1. Para 3.9 discusses visibility to the LEFT when exiting Switzerland Road being measured to the tangent point on the curve of Victoria Road. It is my opinion that this should read visibility to the RIGHT. If this is the case then visibility to the right is acceptable.

1. Para 3.10 to 3.17 discusses the rationale for accepting a reduced x distance of 2.4m rather than 4.5m. As this junction has operated without incident and the visibility to the left is so good at 2.4m the visibility is acceptable.

Car Parking

1. Car Parking standards in the Isle of man are set out in appendix 7 of the Strategic Plan and are set at a level to provide adequate car parking for staff and visitors without resulting in car parking on the surrounding roads that causes congestion or road safety issues. Para 2.10 of the TA correctly states the current standard of 1 space per 15 sqm of nett office space for out of town offices.

1. It is accepted that the environmental objectives of the Strategic Plan may eventually result in a lower car parking standard being applied; a reduction of the current standard may be permissible if it can be demonstrated that this will not result in cars being parked on the surrounding roads contrary to the interests of highway safety.

1. The consultation response attached at appendix A clearly states in point 4 "If the applicant wants to apply a reduced parking standard then I would suggest that a more robust assessment could be made if the applicant carried out a travel to work survey of their existing offices in the vicinity. This would give a clear indication of how people actually travel to work in this area." The submitted TA does not include such a survey and there is no credible justification given for applying a reduced standard. The inference is either that this advice has not been taken or the survey result did not demonstrate that a reduced parking standard would be acceptable.

1. The applicant has chosen to use traffic generation derived from the TRICS database; this database is a collection of actual traffic generation from sites throughout the United Kingdom. The information provided in appendix H page 4 shows the arrival and departure trip rate of vehicles in half hour segments. The maximum number of vehicles on site occurs at 4pm when 270 vehicles have arrived throughout the day and 173 vehicles have departed; this leaves a residual of 97 vehicles on site requiring parking.

1. The proposal includes 80 car parking spaces with an overflow car park of 42 spaces and a separate access onto Switzerland Road on the site of the previous application PA. There are now effectively 122 car parking spaces provided and the full standard has been met. The overflow car park must be retained for use by this development.

Servicing

1. The TA has failed to demonstrate that the site can be accessed by service vehicles without causing disruption to the public highway. The swept path analysis shown on drawing 5741/002 at appendix K has failed to show that a refuse vehicle can negotiate the junction of Victoria Road and Switzerland Road without using both sides of the carriageway. This will cause conflict with other road users and is contrary to the interest of road safety. The alternative route shown on drawing 5741/003 uses a private access road and it is not suitable to service a new

development via private land. The junction of Victoria Road and Switzerland Road should be realigned to accommodate service vehicles.

Sustainability

1. Para 4.3 makes reference to ‘central government publications including DETR ... PPS1 and PPG13’. While the importance of walking is recognized, reference to central government and UK publications in this context is incorrect as the United Kingdom Government and has no jurisdiction in the Isle of Man with regard to planning. The relevant policies should be referenced.

1. Para 4.4 makes reference to ‘Government ... advice’; it is not clear which Government is being referred to and the advice is not referenced.

1. Para 4.7 describes the pedestrian routes to the site and these are acceptable.

1. The facilities provided to encourage cycling to the site are acceptable.

1. Appendix E and F contain the walking and cycling isochrones centered on the site. In both cases the isochrones are have been produced by drawing an arc of the relevant radius centered on the site with no cognizance of actual distance traveled or terrain. Therefore this information is misleading and should not be relied upon to indicate the likely catchment areas for walking and cycling.

1. It is accepted that Victoria Road is regularly served by public service buses linking to the bus station in Douglas and the residential area of Onchan, and the accessibility of the bus routes on Glencrutchery Road is also accepted. However there is a question mark over the accessibility of the bus routes on the Promenade due to the severity of the incline of the pedestrian route between the Promenade and the site.

1. The tables provided in paras 4.12 and 4.13 to demonstrate the frequency of the various services are confusing and when compared to the bus timetable provided at appendix G are not accurate. The inclusion of the entire bus timetable for the Island at appendix G has not been helpful.

1. The assertion in para 4.15 that limited services provided by the Steam Railway, the MER and the horse trams ‘is a useful commodity and future occupants may find the available services advantageous’ is not accepted. These services are provided for tourist use and have little if any commuter service; the horse tram in particular is of little benefit and as it runs along the promenade is accessible only via a steep incline.

Conclusion

1. The Transport Assessment has demonstrated that the traffic generation of the application is acceptable.

1. The Transport Assessment has correctly set out the car parking standard required and the application meets this standard.

1. The visibility splays both from the site onto Switzerland Road and Switzerland road onto Victoria Road are acceptable.

1. The Transport Assessment has failed to demonstrate that the application site can be accessed by service vehicles, particularly refuse vehicles. The junction of Victoria Road and Switzerland Road should be realigned to facilitate refuse vehicles entering and leaving the junction on the correct side of the road.

1. The Transport Assessment has relied upon United Kingdom policy and guidance rather than Isle of Man Strategic Plan to ascertain sustainability.

1. The Transport Assessment has not established the public transport links to the site.

1. The Transport Assessment has not established the walking and cycling distances to the site with specific isochrones that take cognizance of the terrain.

Recommendation

1. The application should be refused on the grounds that it is not possible for service vehicles to access the application site in a safe and appropriate manner in contravention of General Policy 2 sub paragraphs (h) & (i) and Transport Policy 4 of the Isle of Man Strategic Plan.

Prepared by H Fletcher, Traffic Engineer 20th May 2011