Approval in principle for the erection of three dwellings

Policy 5.11

Any future development proposals must take heed of the continuing erosion of the coastline in this area.

e developed for public enjoyment. However, in order to finance this, provision would have to be made for an element of enabling residential development. Inspector's Conclusions 459 Paragraph 5.11.1 of the draft Area Plan records that Wildlife Sites are designated by the Manx Wildlife Trust, with the support of DEFA. As I understand matters, the Tromode Dam Wildlife site has already been designated. Map 1a of the draft Area Plan simply records this, to show where one of the restrictions on development, set out in Environment Policy 4 of the Strategic Plan, will apply. I have seen no technical evidence to indicate that this designation is unwarranted. 460 Although land at Castleward Farm was allocated for recreational, leisure and tourism development in the Braddan Local Plan in 1991, no such development seems to have taken place in the ensuing 28 years. I understand that there would be little prospect of it taking place in future, in the absence of enabling residential development. However, the Strategic Plan indicates that new residential development will be permitted in the countryside only in specified exceptional circumstances, none of which would apply in the present case. In the circumstances, I am not satisfied that there is a case for allocating any part of Castleward Farm for housing, or for development for the purposes of recreation, leisure or tourism, contrary to Strategic Plan policy. That includes the land which is no longer reserved for DHSS requirements. Accordingly, I recommend that no action be taken in response to this objection. Late Site 3 between Braaid Hall and Braaid Cottage, Braaid 461 This site, which measures about 0.06ha, consists of one of four plots which formerly formed part of Braaid Farm. In the 1970s it was granted planning approval for residential development, but this was not taken up. However, the plots on either side have now been developed. The plot to the west is now occupied by the Braaid Young Men's Club Hall. The plot to the east has now been incorporated into the garden of Braaid Cottage, and contains a domestic garage. Late Site 3 is not allocated for development in the draft Area Plan. 462 The owner of this site objected that it was inequitable that this site should not be allocated for residential development. He referred particularly to Section 8.8 of the Strategic Plan, which deals with the potential for additions to be made to existing groups of houses in the countryside. I deal with that matter in paragraphs 237 to 240 above. 463 Braaid is a small cluster of dwellings and other buildings, grouped around a crossroads in a rural area. It is not one of the listed settlements in Spatial Policies 2 to 4 or Appendix 3 of the Strategic Plan. Strategic Policy 2 of the Strategic Plan states that new development will be located primarily within existing settlements, or in sustainable urban extensions to those settlements; and that development in the countryside will be permitted only in specified exceptional circumstances, none of which apply in the present case. Spatial Policy 5 and

General Policy 2

The use of the proposed access from Cooil Avenue would have a detrimental impact upon the residential amenity of the adjacent properties "Cooil Shellagh" and "Melmegsuelyn", contravening part (g) of General Policy 2 of the adopted Isle of Man Strategic Plan 2007.

General Policy 2: 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; (l) 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. 6.3 Development outside of areas zoned for development

Environmental Policy 9

A precautionary approach will be adopted for development relating to land affected, or likely to be affected, by erosion or land instability.

or detract from an archaeological site or its setting will not be permitted. I recommend that Urban Environment Proposal 8 be deleted from the draft Area Plan. Railway Architecture 53 Urban Environment Proposal 9 refers to the protection of station buildings, gate-keeper's huts and other line-side structures. However, it seems to me that if they are worthy of preservation, these buildings should be registered. While I do not doubt their cultural importance, in the absence of their registration, it is not clear to me how the planning authority could prevent their demolition or removal. I recommend that Urban Environment Proposal 9 be deleted from the draft Area Plan. CHAPTER 7 - TRANSPORT AND UTILITIES Highways Traffic Congestion 54 The Area Plan recognises that that there is already traffic congestion at the Quarterbridge junction; at the junction between Mountain Road and Governor's Road; and at the junction between Glencrutchery Road and Victoria Road. The evidence is that if all the development sites identified in the draft Area Plan were to be built-out, and no improvements were made to the road system, there would be a significant increase in congestion in Douglas and Onchan. Modelling commissioned by the Government suggests that, in the worst case, the average speed of traffic during the afternoon peak could decrease from 19mph to 12mph. Some journey times would be likely to increase by more than 100%, when compared with 2016 data. This would affect both private and public transport. However, it seems to me that, in practice, this worst case scenario is unlikely to arise. 55 Opportunities for additional carriageway provision are very limited and none are proposed in Douglas or Onchan in the Area Plan. However, there may be potential for limited highway improvements in the proposed Comprehensive Treatment Areas. Additionally, there is scope for the installation of an improved system of traffic signals, which could improve the capacity of the existing road network, particularly at junctions. Further mitigation could result from the introduction of the Active Travel Strategy, whereby drivers are to be encouraged to walk or cycle to their destinations, where this is practicable. Children living reasonably close to their school could be encouraged to walk there (perhaps in a supervised 'walking bus'); or go by bike. Reduced car use might also be achieved by a modal shift in favour of public transport; or car travellers could be encouraged to share a single vehicle, wherever possible. There may also be increasing scope for some office workers to undertake their duties at home, by making use of IT facilities. 56 Experience has shown that increasing peak period road congestion often results in 'peak spreading', where car users choose to begin their journeys a little earlier (or later) in order to avoid the worst delays. Congestion charging has also been shown to be an effective way of managing peak period delays. However, a degree of peak hour congestion is characteristic of most urban areas, and is perhaps an inevitable consequence of mass car commuting. Cycle Parking and Changing Facilities 57 The Braddan Parish Commissioners argued that the provision of cycle parking and changing facilities should be encouraged at places of employment. I agree. Chapter 11.5.3 of the Strategic Plan already states that 'consideration should be given to cycle parking for staff … in non-residential development'. However, I consider that such provision could appropriately be required as part of a development brief for any proposed employment site. I also consider that employers should be encouraged to introduce Travel Plans, with the aim of reducing the level of car commuting. I recommend that the provision of cycle parking and changing facilities, and the production of a Travel Plan, should be considered for any proposed employment development. Park and Ride 58 The Braddan Parish Commissioners, Miss P Newton and others urged that consideration be given to the introduction of a 'park and ride' scheme, whereby drivers entering Douglas would be encouraged to leave their vehicles at a peripheral car park and complete their journeys by bus. I understand that a previous 'park and ride' scheme had only limited success, and no firm proposal to try again has been put forward by any Government Department. I see no purpose in allocating land for a park and ride facility in the Area Plan, unless there is a good prospect of the requisite investment being made to bring such a scheme to fruition during the plan period. The TT Access Road 59 The TT Access Road provides the sole vehicular route to and from the interior of the TT course when racing is in progress. It is a single track carriageway with passing places, which follows the line of a disused railway, and passes beneath the TT Course near the Quarterbridge junction. Importantly, at race times, it provides the sole means of vehicular access to Noble's Hospital from the greater part of the Isle of Man. I understand that it already becomes 17

Environmental Policy 11

Coastal development will only be permitted where it would not: i) increase or transfer the risk of flooding or coastal erosion through its impact on natural coastal processes; ii) prejudice the capacity of the coast to form a natural sea defence; and iii) increase the need for additional coast protection works

Environment Policy 11: Coastal development will only be permitted where it would not: i) increase or transfer the risk of flooding or coastal erosion through its impact on natural coastal processes; ii) prejudice the capacity of the coast to form a natural sea defence; and iii) increase the need for additional coast protection works except where necessary to protect existing investment or development.

Transport Policy 4

The potential traffic generation from three additional dwellings would be too great on the substandard private access and would have an unacceptable adverse effect on the safety of users of the access and the Cooil Avenue and as such would fail to comply with Transport Policy 4 of the adopted Isle of Man Strategic Plan 2007.

Transport Policy 4: The new and existing highways which serve any n ew development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan. 11.3.2 Notwithstanding policies within this plan which encourage travel by means other than private car it is anticipated that the number of vehicles using the Island's roads will continue to increase. This increase in demand is likely to lead to a greater need for road impro vements in order that travel can take place in a safe, effective, and environmentally acceptable manner. The Department of Transport will continue to assess the need for such improvements to public highways and undertake works where appropriate, with much of the improvement within existing roads carried out under the provisions of the Town and Country Planning (Permitted Development) Order2005. The need for improvements to the Island's highway network must be balanced against the environmental objectives of this plan.