Following careful consideration and a meeting between Friends of Douglas Bay Horse Tramway and Department of Infrastructure Minister Phil Gawne MHK (with subsequent follow up questions about concerns raised by Friends) - here’s our take on the Department of Infrastructure’s current planning application for improving Loch and Harris Promenades, which includes removal without replacement of the horse tramway tracks on those sections, principally to allow for implementation of a modern ‘shared space’ scheme of the same type developed by Ben Hamilton-Baillie for Poynton in Cheshire and then cloned (as urban designers tend to do) for several other UK towns, whilst also maintaining as much free car parking space as possible along the seafront for those vehicle drivers / occupants unwilling to use the town pay & display car parks and walk a little further:
Under the provisions of the Town & Country Planning Act 1999, the Government has a duty to determine which parts of the Island are areas of special architectural or historic interest, the character or appearance of which it is desirable to preserve or enhance.
By means of a statutory instrument (The Douglas Promenades Conservation Area Order 2002), the Government has long recognised and designated the defined area of the Douglas Promenades as a Conservation Area. The special character of this area is described and set out in a written Character Appraisal published by the Government, to be read in conjunction with the map of the Conservation Area attached to the 2002 Order.
The Douglas Promenades Conservation Area Character Appraisal states, under the section entitled ‘Essential Character & Townscape’, that “Synonymous with the image of the Promenades is the unique system of Horse Trams which run the entire length during the summer months. It is judged that this feature makes an important contribution to the special character of the Conservation Area”.
Planning Policy CA/2 requires that when considering proposals for the possible (re-) development of any land or buildings which fall within a Conservation Area, the impact of such proposals upon the special character of the area will be a material consideration when assessing the planning application.
Planning application 16/00379/B submitted by the Department of Infrastructure, which proposes inter alia the repair and resurfacing of the ‘highway’ without retention or reinstatement of any horse tramway tracks along Loch and Harris Promenades, will have a significant diminishing effect on the special character of the Conservation Area, as it removes the necessary infrastructure for the historic horse tramway service to continue running the entire length of the Douglas Promenades.
Furthermore, in our view, the Department of Infrastructure wrongly considers the historic horse tramway as simply part of the public highway along the Douglas Promenades. The horse tramway is in historical fact a discrete rail route centrally positioned along the Douglas Promenades, with the dual carriageway public highway for road vehicles running in each direction along side.
Transport Policy TP/3 provides that development on or around the Island’s historic vintage rail network (including the horse tramway) should in no way compromise its attraction as a tourism and leisure facility nor its POTENTIAL for increased use as a public transport system. Planning application 16/00379/B is contrary to this strategic Government policy.
We are therefore of the opinion that planning application 16/00379/B should be rejected and also that notice should be given to the Department of Infrastructure that removal of (or surfacing over) the existing horse tramway tracks or any part of them as part of a minor works programme will itself require planning approval. Further, the Department of Infrastructure plans should properly take into account at this time, not at a later date, the position of the single tramway track to be reinstated and include the necessary and appropriate facilitating work within the current project phase, otherwise reinstatement of the tramway track along Harris and Loch Promenades at a later date may prove cost prohibitive or completely impractical.
FoDBHT - 17 May 2016