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Applicant: Hesketh Investments Limited Proposal Demolition of the existing former Citadel building, and the erection of a 44 bedroom hotel with associated drainage, refuse bin storage and pick up layby and reinstatement of the adjacent pavements Site Address The Former Salvation Army Citadel Lord Street Douglas Isle Of Man IM1 1LE Case Officer : Mr Chris Balmer Photo Taken: 21.06.2023 Site Visit: 21.06.2023 Expected Decision Level Planning Committee Recommended Decision: Permitted Date of Recommendation 03.08.2023
C : Conditions for approval N : Notes attached to conditions
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
Reason: In the interests of the character and appearance of the Conservation Area, site and surrounding area.
Reason: in the interest of highway safety and ensure adequate lay-by parking provision is provided.
Reason: In the interests of the character and appearance of the Conservation Area and the individual building.
This application has been recommended for approval for the following reason. It is considered that the planning application is in accordance with the relevant planning polices of the Isle of Man Strategic Plan 2016, Area Plan for the East 2020, Section 18(4) of the Town and Country Planning Act (1999), Planning Policy Statement 1/01, Climate Change Act 2021, Our Island and Our Future Isle of Man Visitor Economy Strategy 2022-2032.
Plans/Drawings/Information; This approval relates to the submitted documents and drawings reference numbers all received; 22.05.2023 Design Statement 936-1003 REV 1
23/00616/B Page 2 of 21
Heat Pumps Specification Road Safety Audit Solar PC Panel Specification
18.07.2023
Additional Persons
It is recommended that the following Government Departments should be given Interested Person Status on the basis that they have made written submissions relating to planning considerations:
Head of Visit Isle of Man - Tourism (DfE)
It is recommended that the following persons should be given Interested Person Status as they are considered to have sufficient interest in the subject matter of the application to take part in any subsequent proceedings and are not mentioned in Article 4(2):
1-9 Church Street, Douglas 1 Church Street, Douglas
as they satisfy all of the requirements of paragraph 2 of the Department's Operational Policy on Interested Person Status (2019). ________________________________________________________________
THE APPLICATION IS BEFORE THE PLANNING COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT
1.0 THE SITE - 1.1 The application site is the curtilage of Salvation Army Citadel, Lord Street, Douglas located on a corner plot to the northern side of Lord Street and west of and Lower Church Street & Ridgeway Street. The existing building is a three storey building above street level, there is also an additional basement level, albeit only a small part of the overall footprint of the building. - 1.2 The site in the early 1900s was previously used as a hospital and pub (The Old Brig), all of which was demolished in 1932 - originally two and three storey properties. After the demolition of these two buildings, it is presumed the existing Salvation Army Citadel building on the site was constructed (work had begun on 4th February 1932). - 1.3 The existing hipped roof designed building has some architectural features, including Ashlar-scribed render around the ground and first floor, a string course above first floor level & arched heads above main entrance. The windows within the building have a vertical emphasis with the ground floor and first floor windows continuing up the building as one, while the second floor windows have a more square proportion. None of the windows is original and the existing window pattern is not the original design, which was made up of Georgian panelled windows. - 1.4 There is no existing on-street parking associated with the site.
2.0 THE PROPOSAL - 2.1 The application seeks full approval for the Demolition of the existing former Citadel building, and the erection of a 44 bedroom hotel with associated drainage, refuse bin storage and pick up layby and reinstatement of the adjacent pavements. - 2.2 The proposed three storey building would be sited on a very similar footprint to the existing building, which essentially takes up the majority of the ground area of the site, with the exception of some external bin storage areas. The proposed building would have a front façade facing onto Lord Street and Lower Church Street of approximately 17.5 metres above street level, albeit including the setback plant room it would have a total height of approximately 19metres. The building would be finished mainly in a red facing brick, with contrasting coloured projecting snapped header brick courses and cast stone cornice dentils and string courses with brick infill. The rear elevation (north) would be finished in painted render. The windows are proposed to be grey upvc sliding sash. - 2.3 The building, with the use of different finishes, glazing proportions and flush dormer details has a vertical emphasis. The building has a flat roof, as the majority of the roof area would be utilised to accommodate a plant rooms (internal and an external) which externally finished with baffled polyester powder coated louvres. Solar panels are also included on the roof. - 2.4 No off street parking is proposed to be provided by this development; albeit it is proposed to alter the footpath along the Lord Street elevation of the proposal to enable a lay-by being created. The ground floor of his section of the hotel is setback into the site more than the upper floor to enable a 2m wide public footpath is provided.
3.0 PLANNING HISTORY - 3.1 The following previous planning applications are considered to be specifically material in the assessment of the current application: - 3.2 Demolition of existing Citadel building and the erection of a replacement worship building with associated administration, practice spaces, meeting areas and nursery 17/00186/B - APPROVED (04.04.2017). - 3.3 Registered Building consent for the demolition of former citadel building (in connection with PA 23/00616/B) - 23/00617/CON - PENDING CONSIDERATION - 3.4 Replacement of existing with PVC windows, Salvation Army Citadel - 94/01619/B APPROVED - 3.5 Internal alterations to improve facilities - 92/01360/B - APPROVED
4.0 DEVELOPMENT PLAN POLICIES - 4.1 The application site is within an area zoned as "Mixed Use Proposal Areas - Strand Street" identified on the Area Plan for the East 2020. The site is within a Conservation Area. The existing building is not a Registered Building, nor proposed to be. Douglas Town Hall located to the northeast of the site is a Registered Building. The site is not within a high flood risk zone. The adjacent highway to the east and sections of Lord Street to the southeast are within an area of high risk of surface water flooding. Given the nature of the application it is appropriate to consider the following planning policies: - 4.2 Strategic Policy 1 states: "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(1) and amenity standards; and (c) being located so as to utilise existing and planned infrastructure, facilities and services."
4.3 Strategic Policy 2 states: "New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(2) of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3." - 4.4 Strategic Policy 4 states: "Proposals for development must: (a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings(1), Conservation Areas(2) , 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." - 4.5 Strategic Policy 5 states: "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." - 4.6 Strategic Policy 10 states: "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" - 4.7 Spatial Policy 1 states: "The Douglas urban area will remain the main employment and services centre for the Island." - 4.8 General Policy 2 states: "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:
4.9 Environment Policy 35 states: "Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area,
4.19 Mixed Use Area 3 - Strand Street; "This area forms the core of the retail shopping area and is characterised by shops, food and drink uses, financial and professional services and other associated town centre uses such as hairdressers, beauticians and so on. The area is currently busy during daytime but quiet of an evening and it is considered that more residential uses would benefit the area and help 25 GD 2014/83 86 support the night time economy. The primary shopping frontage is notated by the hatched line on Map 5." - 4.20 Town Centre - Mixed Use Proposal 3 states; "There will be a presumption in favour of retail and ancillary town centre uses such as food and drink and health and beauty uses along the primary shopping frontage. Outside of the primary shopping frontage a wider variety of town centre uses including financial and professional services open to visiting members of the public will also be acceptable. Entertainment venues, Offices and residential use will be acceptable at first floor level and above, but not at ground floor level where an active frontage should be maintained and enhanced. These active frontages are essential to sustain an attractive town centre." - 4.21 LEGISLATION - It is relevant to note Section 18(4) of the Town and Country Planning Act (1999) states, "(4) Where any area is for the time being a conservation area, special attention shall be paid to the desirability of preserving or enhancing its character or appearance in the exercise, with respect to any buildings or other land in the area, of any powers under this Act." - 4.22 Conservation Areas of Planning Policy Statement 1/01 (Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man); "POLICY RB/6 DEMOLITION There will be a general presumption against demolition and consent for the demolition of a registered building should not be expected simply because redevelopment is economically more attractive than repair and re-use of an historic building; or because the building was acquired at a price that reflected the potential for redevelopment, rather than the condition and constraints of the existing historic building. Where proposed works would result in the total or substantial demolition of a registered building, an applicant, in addition to the general criteria set out in RB/3 above, should be able to demonstrate that the following considerations have been addressed:-
carefully considered. The challenge presented by retaining registered buildings can be a stimulus to imaginative new designs to accommodate them
POLICY CA/6 DEMOLITION Any building which is located within a conservation area and which is not an exception as provided above, may not be demolished without the consent of the Department. In practice, a planning application for consent to demolish must be lodged with the Department. When considering an application for demolition of a building in a conservation area, the general presumption will be in favour of retaining buildings which make a positive contribution to the character or appearance of the conservation area. Similar criteria will be applied as those outlined in RB/6 above, when assessing the application to demolish the building, but in less clear cut cases, for example, where a building could be said to detract from the special character of the area, it will be essential for the Department to be able to consider the merits of any proposed new development when determining whether consent should be given for the demolition of an unregistered building in a conservation area. Account will be taken of the part played in the architectural or historic interest of the area by the building for which demolition is proposed, and in particular of the wider effects of demolition on the building's surroundings and on the conservation area as a whole."
4.23 Climate Change Act 2021 which sets a target year of 2050 and to make provision for the setting of interim targets for the reduction of greenhouse gas emissions; to make provision about the mitigation of climate change and the enhancement of natural carbon storage; to impose climate change duties on public bodies; to make provision for energy generation and energy use and for the reduction and recycling of waste; and for connected purposes. - 4.24 Our Island, Our Future Isle of Man Visitor Economy Strategy 2022-2032 - DfE which indicates its target is; "Our headline targets are to grow our annual visitor numbers to 500,000 by 2032 and increase the annual economic contribution of the Island's Visitor Economy to £520m. This will mean attracting an additional 170,500 visitors per year compared to 2019. We aim to triple our holiday and short break market as well as grow all of our other visitor markets. Combined with an expected increase in average spending per visitor, driven by strong growth in longer staying and higher spending leisure markets, these visitor numbers should result in a more than doubling of annual visitor spending on the Island to £310m, which will support an increase in Visitor Economy jobs to 5,000 and generate an annual Exchequer benefit of £49m."
5.0 CONSULTATIONS - 5.1 Highway Services initially commented (08.06.2023); "The proposal is acceptable in the main. Refinements are necessary to external doors / gates for the bicycle parking. Additionally, confirmation of the suitability of the cycle storage is required and alterations to the storage access to and from the hotel. Modifications are necessary to the layby on Lord Street to fully satisfy the highway requirements for a width adequate to take a large van to meet the route's functional objectives and provide suitable arrangements for delivery and collection other than for waste bins. A pavement café could be considered for Church Street. Separate permissions would be necessary after grant of planning consent for highway works, uses of the highway during demolition, construction, pavement café and oversailing, plus TRO's on operation. Recommendation: Revisions"
An s109 agreement will be required for the highway works, plus a TRO is required for the proposed parking restrictions.
Permissions for use of the highway during demolition and construction will be required. Licences will be required for oversailing of the highway by the proposed building (and any overhanging hotel signs) on Lord Street, and for any future pavement café on Church Street.
Conclusion: The proposal is acceptable with conditions. A pavement café could be considered for Church Street. Separate permissions would be necessary after grant of planning consent for highway works, uses of the highway during demolition, construction, pavement café and oversailing, plus TRO's on operation. Recommendation: DNOC"
5.2 Douglas Borough Council have resolved to support the application (17.08.2023). - 5.3 Principal Registered Building Officer comments (02.08.2023); "The Former Salvation Army Citadel dates to the early 1930's, replacing a pub and hospital that were demolished to make way for the existing building. The building sits comfortably upon the corner plot, has a large one and half storey ground floor with first floor and hipped roof above. It has some architectural features, including Ashlar-scribed render at ground with string course above, with arched headed main entrance on the street corner elevation. Like its architectural detail, the buildings contribution to the character and appearance of the conservation area is considered to be modest.
The application seeks full approval for the demolition of the existing former Citadel building, and the erection of a 44 bedroom hotel with associated drainage, refuse bin storage, pick up layby and reinstatement of the adjacent pavements.
The benefits of the proposed new development should be weighed against the loss of the building and the overall impact upon the character and appearance of the conservation area.
Whilst the proposed building is clearly inspired by neighbouring buildings that provide the character and appearance of this part of the conservation area, the success of the overall development would be dependent upon the quality of the materials used and the final detailing, the brick type, the bond pattern and contrasting string coursing. The building's overall design is let down by the fourth floor, the detailing of which appears tokenistic, with flat pedimented detailing. Had there been true pedimented dormers sitting upon a more recessed roof, they would have been more successful, this would have resulted in a true breaking up of massing rather than a visual attempt at one.
If you are minded to approve the application, please ensure materials and bonding pattern are conditioned to ensure the quality of new development within a conservation area."
5.4 Ecosystem Policy Officer comments (06.06.2023); "The Ecosystem Policy Team have no objections to this application, but due to the age and condition of the building, we would like to alert the applicants to the potential for nesting birds in and around the building - birds including house sparrow and starling in any external gaps, and house martins underneath the eaves. So thorough checks for nesting birds must be undertaken in and around the building prior to its demolition. If nesting birds are present the demolition must wait until the birds have finished nesting and the young have fledged.
The bird nesting season is usually between late February and late August or September in the case of swallows or house martins. Additionally, pigeons have been known to nest year-round should conditions be suitable. Due to the height of the new hotel building, we also really strongly recommend that the applicants consider installing universal swift nest bricks (at least 3) in the new building, as high up as possible, under the eaves on a north-east to north-west elevation, but not above windows. Not only will these universal bricks provide nesting space for swift, but they are also suitable for house sparrow, starling and house martin and so will provide mitigation for the loss of nesting space for any birds that are currently present."
5.5 Head of Visit Isle of Man - Tourism (DfE) make the following comments (01.06.2023); "This comment has been provided by Officers from within the Visit Isle of Man Agency and as such, should be considered as Officer comment only and, therefore, not the view or official position of the Visit Agency Board, or political members of the Department for Enterprise.
The Our Island Our Future Visitor Economy Strategy 2022-2032, endorsed by Tynwald in May 2022, includes a Visitor Accommodation Transformation Action Programme that seeks to develop 500 new and transformed hotel and serviced accommodation bedrooms and 500 new units of distinctive, contemporary, eco-friendly non-serviced accommodation to support visitor number growth over the next 10 years.
Programme 3 (Visitor Accommodation Transformation) of the strategy highlights that our visitor accommodation studies have shown that we are lagging behind our competitor island, coastal and rural destinations in terms of the quality and choice of visitor accommodation that we offer.
Investment needs to be secured in distinctive, contemporary and ecofriendly visitor accommodation that will attract new visitor markets to the Island, help to boost off-peak demand, and enable the Island to get ahead of the competition.
The development would see the creation of a 44 bedroomed hotel with ancillary facilities including ground floor restaurant and bar.
The Our Island Our Future Visitor Economy Strategy states that our priority to 2032 will be to triple our holiday and short break demand with over 70% of our additional visitors staying for such purposes. The strategy has four target markets to grow and attract including 'Traditional Traveller', 'Curious Explorers', 'Experience Seekers' and 'Family Adventurers'.
Development of new hotel accommodation will add to the growth of these markets, specifically the 'Family Adventurers' who look for family-orientated accommodation. Documents '2300616B APL Drg P02revA Proposed Basement Ground First Second Floor Plans' and '2300616B APL P03revA Proposed Third Fourth Floor Rooftop Plant Plan Section A-A' on the planning application shows a number of interconnecting rooms on every floor which would satisfy the family market. There is also a proposed accessible bedroom which will add to the Island's accessible bed stock, which shows alignment with the Equality Act 2017. At present, the Isle of Man has a limited number of family friendly and accessible bedrooms within the serviced sector.
Document '2300616B APL Design Statement Part 1 of 2' on the planning application breaks down the Economic Benefits of the hotel development including the number of jobs being
created (16 full-time employees with an average salary of £30k). The creation of jobs supports Visit Isle of Man to achieve its targets under Programme 7 (Talent Development) of the Our Island Our Future Visitor Economy Strategy.
The need for new hotel developments is further supported by the Department's commitment within the Enterprise Act 2008 highlighting 'new hotel accommodation 3* and above (whole business, sole business)' as eligible for financial support and encouraged. The justification is as follows:
From an Area Plan perspective, we note that the site is located within the Strand Street Mixed Use Area designated in the Area Plan for the East approved by Tynwald on the 18th November 2020, and the redevelopment of the site for visitor accommodation is entirely in keeping with that designation. We also note that the site proposals are to redevelop an unoccupied urban site, which is not included on the formal Unoccupied Urban Sites Register, does deliver on the Island Plan's strategy to redevelop our brownfield sites.
It is anticipated that the development would achieve a high quality finish satisfying a number of elements highlighted as growth potential within strategic documentation which will be in sympathy with the Departments policy to encourage a quality visitor experience to ensure the Island remains a competitive as a destination.
For the reasons set out above, Visit Agency Officers are thus fully supportive of this application…"
5.6 The owner of 1-9 Church Street objects to the application which can be summarised as (08.06.2023); This building can be saved, I personally viewed the premises, and over many months attempted to purchase with the intention of converting the building to apartments for residential use; This building needs Registered Building Consent to enable demolition. This should be refused as it is a major landmark for Douglas, our heritage should be protected not destroyed; I also have concerns regarding the height of this proposed building, which is out-of keeping with the existing conservation area; and I own 1-9 Church Street and any demolition and rebuilding would greatly affect my Property, Tenants, Trade etc, and I strongly urge refusal of this application.
5.7 The letting agents (based at 1 Church Street) of 1-9 Church Street objects to the application which can be summarised as (12.06.2023); The property we manage stretches from the Salvation Army building to and including half of the Rovers Return; Ourselves and all present tenants wish to object to the demolition of the Salvation Army Citadel and the construction of a hotel; We feel that demolition would ruin our businesses as work would affect our private lane, known as Church Street, which is used consistently as means of access to our premises; A hotel again during construction would again affect access to our lane, and when and if in use, our private lane would be in danger of being a focal point and constantly used by the hotel; and All tenants and of course ourselves Church Street Rentals strongly object to both applications and trust that they are rejected. - 5.8 In response to the objections received the applicant have made the following summarised comments (20.07.2023);
Impact on neighbouring Properties and Businesses - The demolition and construction of the new hotel will be undertaken in a manner that is sensitive to the neighbouring properties and businesses. The developer Mr Lord has much experience of town centre development and these developments were all in challenging town centre locations on busy streets with shops and restaurants nearby, and there were never any issues during demolition nor construction works;
Value of Existing Building - The existing building whilst it sits comfortably in the street-scene it cannot be claimed to be of any architectural significance as outlined by the previous planning officer for application 17/00186/B; we also undertook a pre-application consultation with the Registered Buildings Officer and there was no objection to the demolition of the existing building. Therefore we believe the proposed development also complies with EP39;
Strategic Policy 1 - The proposed building design does comply with this policy. The new building optimises the use of a previously developed site which has a building that is no longer in use, and due to its previously specific design and being landlocked, it is not conducive to being repurposed and has become redundant. The new design is a more efficient use of the site and by its location it utilises the existing infrastructure facilities and services. Strategic Policy 8 - The development does comply with this policy as the existing building has been assessed by a Senior Planning Officer under PA17/00186/B, and found to be of little 'interest and quality'.
Strategic Policy 3/General Policy 2/Environment Policy 42 - The new building design 'respects the site and the surroundings' as we have used some existing architectural elements from adjacent buildings - red brick with contrasting bands for the Old Hanover Street School Building, white stone from the Town Hall and arched pediments from the eaves of Falcon House. All of these features combine to create a building design that is contextual in the townscape and respectful of its setting; and has made use of local materials and character. The building is designed to respect the scale of the two adjacent buildings - the top of the red brick on the facades aligns with the eaves of the Old Hanover Street School, and the kneeler copings at the eaves of no. 1 Church Street and above the red brick the materials of the façade changes to a metal cladding, reducing the visual impact of the facades. This can be seen on the visuals with the application. The building's scale is therefore respectful of its neighbours. The building is designed to be thermally efficient and also makes use of low carbon green energies as there are two banks of solar PV panels on the roof and the heating and hot water is provided by a number of air to water and refrigerant heat pumps on the roof. The design does comply with SP 3, GP2 and EP42.
Strategic Policy 10 - The layby has been designed by transport consultant i-Transport, and they have used vehicle tracking to show the layby has no adverse impact on the highway. The layby has also been assessed as part of a Road Safety Audit and found to be suitable.
Environment Policy 13 - There is a low likelihood of surface water flooding along Church Street and onto Lord Street. It is not expected to affect the new building as this flooding is mainly in the highway and windows sills and doors thresholds are set above pavement level. Therefore there is a low risk from flooding and therefore the development complies with EP13.
6.1 The main issues to consider in the assessment of the application are; principle of the development; principle of the demolition of the existing building; potential impact upon the street scene and Conservation Area; potential highway issues/parking provision; energy policy; and potential ecology issues. PRINCIPLE OF THE DEVELOPMENT - 6.2 As outlined within the Area Plan for the East the site is designated within an area of Mixed Use. Within the Written Statement accompanying the Area Plan paragraph 3.4.2 states; "…The town centre will be revitalised through regeneration work and encouraging high quality retail development. New leisure and hotel facilities will attract tourists and provide an attractive and vibrant mix of uses within Douglas." - 6.3 Tourism Proposal 1 states indicates that; "There is a recognised need for the renewal of the Island's hotel offer through investment in existing stock and some new hotel provision…". Tourism Proposal 2 states that; "The establishment of new or alterations to, existing tourist accommodation within the settlement boundaries in the East will generally be supported. New development should be of a high design standard, have an active ground floor frontage and be accessible to those with disabilities. They should incorporate, where appropriate, improvements to the public realm, e.g. outside seating, public art and hardy landscaping designed for longevity." - 6.4 This proposal would meet the aims of these policies. This view is supported by the Head of Visit Isle of Man and the benefits this size and type of new hotel would provide. - 6.5 While Mixed Use Area 3 - Strand Street does not specially indicated hotel uses, albeit indicates that; "This area forms the core of the retail shopping area and is characterised by shops, food and drink uses, financial and professional services and other associated town centre uses such as hairdressers, beauticians and so on…" Further Town Centre - Mixed Use Proposal 3 states; "…Outside of the primary shopping frontage a wider variety of town centre uses including financial and professional services open to visiting members of the public will also be acceptable. Entertainment venues, Offices and residential use will be acceptable at first floor level and above, but not at ground floor level where an active frontage should be maintained and enhanced. These active frontages are essential to sustain an attractive town centre.". As mentioned previously, while hotel use is not specifically mentioned, it is considered a hotel use with ground floor restaurant (37 covers) and a bar (27 covers) occupying the majority of the ground floor with active frontages (large glazed windows at ground floor) and 44 bedrooms above are considered to meet the overall aims of the Area Plan for the East. Further, the introduction of a hotel within this central location would not be out of character of the mixed uses in the immediate area. Accordingly, it is considered the principle of a hotel, bar and restaurant is appropriate in this location. PRINCIPLE OF THE DEMOLITION OF THE EXISTING BUILDING - 6.6 As outlined within Environment Policy 39 (and Planning Policy Statement 1/01), there is a general presumption will be in favour of retaining buildings which make a positive contribution to the character or appearance of the Conservation Area. Furthermore, paragraph 7.32.2 of the IOMSP indicates; "The general presumption will be in favour of retaining buildings which make a positive contribution to the character or appearance of the Conservation Area. When considering proposals which will result in demolition of a building in a Conservation Area, attention will be paid to the part played in the architectural or historic interest of the area by the relevant
building and the wider effects of demolition on the building's surroundings and on the Conservation Area as a whole. In addition, consideration will be given to:
6.7 The existing Salvation Army Citadel building on the site was constructed (work had begun on 4th February 1932). The building is currently appears in a poor state of repair, albeit not in a state of disrepair. A material consideration is the principle of the building being demolished and replaced was accepted under planning application. The Planning Officers report indicated; "It is considered that the existing building does not have a significant architectural interest, albeit does not appear unattractive within the street scene and arguable sits quietly within the street scene. The Conservation Area appraisal simply refers to the building as "a thinly detailed 1930s building which nevertheless presents a firmly massed corner to Lord Street and has a good rusticated ground storey". Given the building does not have any significant architectural interest neither is it registered building (nor potentially list to be). Accordingly, it is considered the principle of the demolition of the building is acceptable." - 6.8 The applicants have not specially addressed the first three points within paragraph
7.32.2, albeit have indicated that; "The existing Citadel building is not suitable for renovation into a new hotel. The internal plan layout is restrictive, and its structure is not conducive to internal reconfiguration of spaces. The headroom on the upper floors is too low for a modern highly serviced hotel. The building at only three storeys above the ground could not provide the required number of bedrooms to achieve an economically sustainable hotel business."
"The existing building whilst it sits comfortably in the street-scene it cannot be claimed to be of any architectural significance."
6.10 As outlined, Environment Policy 39 & PPS1/01 indicates that buildings that make a positive contribution to the character or appearance of the Conservation Area should generally be retained. In this case for the reason outlined, it is not considered that the building has any significant architectural interest or historical interest to seek its retention. While the application does not go into specific detail in terms of; the condition of the building, the cost of repairing and maintaining it in relation to its importance and the issue derived from its continued use or the adequacy of efforts made to retain the building in use; the design statement does state that the internal plan layout is restrictive, the existing structure is not conducive to reconfiguration and that headroom on the upper floors is not suitable. With these things in mind, it is reasonable to ascertain that the level of accommodation proposed would not be physically accommodated within the existing building. - 6.11 There is also an argument that while there are four key considerations (par 7.32.2 of the IOMSP), the text before these four points states; "In addition, consideration will be given to; …". Accordingly, it could be argued that in certain cases one or more of the considerations could potentially have greater weight. In some circumstances it could be determined that the "merits of alternative proposals for the site" i.e. a new building is of such a high quality could override the other three points, especially if the building did not make a positive contribution to the character or appearance of the Conservation Area. If the building was a Registered Building and/or a building of special architectural interest or historical interest; then there would be greater importance to ensure all the points had been adequately addressed. However, the lack of information for the three points indicated do weigh against the proposal.
6.12 As outlined the merits of alternative proposals (will be considered later in this report) for the site are a consideration and which could overcome the outstanding issues indicated. - 6.13 However; given the comments of the Registered Building Officer, previously the principle to demolish the existing building has been accepted and as the existing building is not considered to be of significant architectural interest or historical interest to seek its retention nor to make a particularly positive contribution to the character or appearance of the Conservation Area, once again it is considered the principle of the demolition is acceptable on this site. POTENTIAL IMPACT UPON THE STREET SCENE AND CONSERVATION AREA - 6.14 The Planning Authority has a duty to determine whether such proposals are in keeping with not only the individual building, but the special character and quality of the area as a whole. With this in mind it is very relevant to consider Environment Policy 35 of the Isle of Man Strategic Plan (adopted June 2016). This policy indicates that development within Conservation Areas will only be permitted if they would preserve or enhance the character or appearance of the Area, and will ensure that the special features contributing to the character and quality are protected against inappropriate development. Furthermore, it is necessary to apply the Conservation Area statutory test as referenced in section 4.20 of this assessment on whether the proposal would preserve or enhance the Conservation Area. - 6.15 General Policy 2 also indicates that any development should; respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them and should not affect adversely the character of the surrounding landscape or townscape. - 6.16 The new building in terms of its front facades onto Lord Street and facing towards Ridgeway Street would be taller (approximately 4m and 7m including setback roof plant building) and therefore the proposed building would have a greater presence and mass on this prominent corner within Douglas. Again, planning application also proposed a building taller than the existing; albeit the current application the building is taller (approximately a storey higher). The new building would have a roof height (not including roof plant structures) of the neighbouring building The Government Officers (formerly Old Hannover Street School). - 6.17 The finishes of the building take reference to a variety of styles and finishes in the immediately street scene. The red brick (and other colours) are very evident in a number of neighbouring properties, including the Douglas Town Hall, The Ridgeway Building, Merchants House and The Government Officers (formerly Old Hannover Street School). However, there are a variety of different material pallets and colours used in the immediate area already, including; Manx Stone, render (both smooth and rough cast), brick & pebble dash. Furthermore, some of the nearby buildings use a mixture of the finishes listed, while others are finished in one type only. Overall, the finishes proposed are considered appropriate and would fit well within the various street scenes. - 6.18 The design, form, scale and heights of buildings in the area again vary from two storeys up to six storeys, the majority being older three storey properties. The neighbouring Government Officers are three storey but substantial in height, and would have a similar height to the proposed building. The other neighbouring property to the north of the site Nr 1 Church Street would be approximately 0.40m lower than the proposal (excluding plant room - proposal would be 3.40m taller if plant room is included). While the proposal would be taller than Nr 1 Church Street, it is not considered this would result in an adverse visual impact or inappropriate form of development. The proposed new building sits on a corner plot and it is not unusual to find a taller building compared to other properties in the area. Arguable, that is perhaps an issue with the existing building, being lower than the two neighbouring properties resulting in a
6.25 The Transport Statement highlights that the previous use of the building operated without parking spaces for the following uses;
6.26 The statement includes a trip generation which has been calculated using similar sized hotels in comparable locations to establish the likely number of person trips and the mode split for both staff and guests and in accordance with the guidance set out in the Manual for Manx Road for such calculation. The trip generation indicates that it is anticipated that a total of 94 two way vehicle movements (taxis, cars, service vehicles etc) would occur on a daily basis, of these 10 would be AM peak movements and 14 would be PM peak movements. It is anticipated most people arriving by foot (295 movements) and 32 people arriving by public transport. - 6.27 The statement also includes anticipate usage of the proposed drop off and pick up layby fronting the site. It is anticipated that a total of 32 two way movements would use the layby on a daily basis, mostly taxis and servicing/delivery vehicles, with typically one arrival and departure per hour for the majority of the day. The applicants indicate that; "Taxis are expected to set down for a maximum of five-minutes to allow luggage to be unpacked and for payment to be made. On this basis, a minimum of 12 taxis arrivals/departures will be able to use the proposed lay-by in any one hour. Information provided by the applicant indicates that the maximum dwell time per delivery vehicle is approximately 20 minutes. And On this basis, even in the unlikely event two or three delivery vehicles should arrive within the same hour, the proposed lay-by bay will be sufficient to accommodate the expected drop-off and delivery movements." - 6.28 The Transport Statement also includes details of public car parks near to the site (within walking distance for staff and visitors), these include; Shaw's Brow Car Park (120m), Tongue (400m), Parade Street East Car Park (500m), Bottleneck (600m). The highlight the "Douglas City centre Parking Study and Parking Policy Development Options' report, November 2013, prepared by Amey/TPi on behalf of DoI" which reviewed the existing car parks and their capacity located within Douglas City centre. The above car parks on a Friday (highest peak in a week day) on averaged where 80% at capacity (165 spare spaces) and on a Saturday had a 27% capacity (616 spare spaces). The applicants therefore consider that this demonstrates there is ample spare off-street parking capacity within a reasonable walk of the site on both a weekday and Saturday in order to accommodate the expected small number of vehicle movements generated by visitors and staff at the proposed hotel. The statement also highlights that since 2013 when the parking report was undertaken; "The sustained rise in home working / flexible working and online retailing as a result of the change in travel behaviour due to Covid-19 has accelerated trends in Active Travel and is likely to have assisted in achieving a long-term reduction in parking demand within Douglas. The use of 2013 travel characteristics is therefore considered to be robust." - 6.29 The applicants statement also indicates that the site is within the town centre and is high accessible by alternative modes of travel and is within close proximity to a number of bus stops and the main bus station on Lord Street, which has direct links throughout the IOM and the Airport. - 6.30 The submitted Transport Statement concludes that; "Having regard to the analysis contained in this document and in accordance with the requirements of the Isle of Man Strategic Plan 2016, it is concluded that there are no valid highway or transport reasons for objecting to the proposed development. The development proposal:
6.31 It is also important to consider that the principles of the IOMSP seek for sustainable development and that Transport Policy 1 which seeks that new development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes. The preamble to this policy is paragraph 11.2.3 which states that to meet environmental objectives new development should where possible be located and planned so as to reduce the need for travel and encourage means of travel other than by private car, in particular walking, cycling, and public transport use. It further goes on to state that such sites should be within or contiguous with existing built centres which are well served by public transport and which are within walking or cycling distance of the new development, and this will have the added benefit of strengthening the services, shops, employment opportunities and overall vitality of those centres. These aims are essentially replicated by the Active Travel Strategy approved by IOM Government and which the Area Plan for the East relies heavily one as well (see policy section of this report). - 6.32 The application includes secure covered cycle storage as well as shower/changing facilities for members of staff. Bus stops are almost immediately adjacent to the site (outside Douglas Town Hall) or within very close proximity to the main bus station on Lord Street. Arguably, the application site is in one of the most sustainable locations on the Island and therefore it would be reasonable to conclude that if any site /development meet the sustainable aims of the IOM Strategic Plan, Active Travel Strategy and the Area Plan for the East, it is this proposal. - 6.33 Significant material consideration is given to Highway Services comments who raise no objection to the application in terms of traffic generation, the proposed lay-by or the lack of parking provision. They consider the application to be acceptable subject to conditions listed. - 6.34 Overall, while the proposal would not provide on-site parking it is considered the hotel use on this specific site, located in the centre of town, close to public transport links and good sustainable links, would all help meet the overarching aims of the IOMSP which seeks to promote sustainable development and travel which seeks to reduce the need for travel and encourage means of travel other than by private car, in particular walking, cycling, and public transport use. ENERGY POLICY - 6.35 In accordance with Energy Policy 5 the applicants have submitted an Energy Statement which outlines all the energy reduction and efficiency measures proposed to be undertaken, some of which are; High performance building fabric and energy efficient lighting; Passive design measures to reduce energy demand for heating, cooling, ventilation and lighting; ASHPs; Heat recovery on mechanical ventilation system; Building management control system; Roof mounted PV; and LED Lighting. The Building has also been design to meet current Building Regulation Standards. - 6.36 The submission includes details for 13 solar panels mount at roof level, 3No Air Source Heat Pumps and 4 No refrigerant based air source heat pumps within the external plant area (uncovered). - 6.37 For information, such details are now recommended to be included in any current planning application, as they are individually regarded as development and require planning approval. If they were not shown on the current plans and then would be needed to be installed later due to impending deadlines (see below), then there is the potential the entire application for the whole scheme including the non-fossil fuel heating systems would need to be re submitted. The impending deadlines are 1st January 2024 all Building Regulation Applications
will not approval a fossil fuel heating system in any new build and on the 1st January 2025 it will be illegal to install a fossil fuel heating system in any new building (can also include extensions if a new heating system is being installed within that extension).
Potential Ecology impacts
6.38 As outlined within the comments of the Ecosystem Policy Officer, while they have no objections they raise potential for nesting birds (house sparrow, house martins and starling) in and around the building and therefore thorough checks for nesting birds must be undertaken in and around the building prior to its demolition. If nesting birds are present the demolition must wait until the birds have finished nesting and the young have fledged. The bird nesting season is usually between late February and late August or September in the case of swallows or house martins. A noted should be attached advising the applicants of the above as well as possible universal swift nest bricks (at least 3) in the new building. OTHER MATTERS - 6.39 It is noted that comments have been received in terms of impacts upon neighbouring properties and business of the construction works. While the concerns raise are very understandable, these matters are not material planning matters that can be considered in the determination of the application.
7.1 For the reasons outlined above it is considered that the planning application is in accordance with the relevant planning polices of the Isle of Man Strategic Plan 2016, Area Plan for the East 2020, Section 18(4) of the Town and Country Planning Act (1999), Planning Policy Statement 1/01, Climate Change Act 2021, Our Island and Our Future Isle of Man Visitor Economy Strategy 2022-2032 and it is therefore recommended that the planning application be approved. - 8.0 INTERESTED PERSON STATUS
8.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:
8.2 The decision maker must determine:
8.3 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given Interested Person Status.
I can confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to the it by the appropriate DEFA Delegation and that in making this decision the Committee has agreed the recommendation in relation to who should be afforded Interested Person Status.
Decision Made : …Permitted……….... Committee Meeting Date:…21.08.2023
Signed :…………C BALMER………….. Presenting Officer
Further to the decision of the Committee an additional report/condition reason was required (included as supplemental paragraph to the officer report).
Signatory to delete as appropriate YES/NO See below
Customer note
This copy of the officer report reflects the content of the file copy and has been produced in this form for the benefit of our online services/customers and archive records.
PLANNING COMMITTEE DECISION 21.08.2023 PA No 23/00616/B Applicant Hesketh Investments Limited Proposal Demolition of the existing former Citadel building, and the erection of a 44 bedroom hotel with associated drainage, refuse bin storage and pick up layby and reinstatement of the adjacent pavements Site Address The Former Salvation Army Citadel Lord Street Douglas Isle Of Man IM1 1LE Principal Planner Presenting Officer Mr Chris Balmer
As above
Addendum to the Officer Report
The Planning Committee approved the planning application subject to Condition 5 being amended to;
C 5. The covered footway adjacent to the proposed lay-by on Lord Street as shown on drawing P-01-Rev B shall remain free of obstructions for the lifetime of the building and details of lighting shall be submitted to and approved by the Department and this approved lighting scheme shall be completed prior to the occupation of the Hotel and retained thereafter.
Reason: in the interest of highway safety.
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