Planning Statement Port Erin Royal Hotel

Planning Statement

Replacement of former hotel building with a scheme of Residential Apartments, Port Erin Royal Hotel, The Promenade, Port Erin.

HERITAGE <br> HOMES

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Isle of Man Business Park, Cooil Road, Braddan, Isle of Man, IM2 2SA

• Introduction

1. This application seeks detailed planning permission to redevelop the site of the former Port Erin Royal Hotel with a scheme of 34 residential apartments. The existing hotel building has been disused since 2008 and planning approval in principle was granted in 2009 to redevelop the site for residential purposes.

1. The proposed new building has been designed to take account of its context, and pre-application consultation has taken place with a number of relevant parties including the Planning Authority, the Highway Authority, Port Erin Commissioners, local MHKs and neighbouring residents.

1. This statement considers the planning issues which are relevant to the proposal, including the planning history of the site and its planning policy context. The application is also accompanied by a Design Statement, and a Transport Assessment prepared by Bryan G Hall Consulting Civil & Transportation Planning Engineers.

The Site

1. The Port Erin Royal Hotel building is one of a series of tall buildings on the eastern side of the Promenade in Port Erin which face westwards to overlook the open brooghs and Port Erin Bay. The buildings in this area were originally Victorian hotels, but many have now been replaced with more modern structures which accommodate residential apartments.

1. The Port Erin Royal Hotel is one of the remaining Victorian structures and has been disused since 2008. It generally consists of a main building which varies between three and five storeys in height and a large rear outlet of four storeys, along with a number of smaller outbuildings. An area immediately to the south east of the rear outlet, which previously accommodated a swimming pool building and car parking for the hotel, has recently been redeveloped with modern townhouses.

1. A cul-de-sac known as Rowany Villas runs along the northern side of the hotel building, and provides access to a small number of residential properties. The vacant plot which adjoins the northern side of the junction between the Promenade and Rowany Villas was formerly occupied by the Ocean Castle Hotel and is now the site for an approved apartment scheme. Princess Towers, a relatively modern apartment building which varies between five and six storeys in height, is located immediately to the south of the Port Erin Royal.

1. The hotel site is located within a residential area which, in addition to modern apartment buildings overlooking or close to the Promenade, accommodates a variety of dwelling types. Links Close adjoins the site to the east and is characterised by single storey dwellings which are set at a higher level than much of the site, whilst the dwelling on Rowany Villas known as Eastfield House (which adjoins the north eastern corner of the application site) is a three storey dwelling. The recently developed townhouses on the former site of the hotel swimming pool have three levels of accommodation.

1. The highways in the vicinity of the site are described in detail in the Transport Assessment which accompanies the application. The highway which runs in

front of the application site (The Promenade) carries traffic in both directions and has a footway on either side. Parallel on-street car parking takes place on the western side of the highway, as well as in marked echelon pattern spaces on Rowany Villas.

Planning History

1. Planning approval in principle has previously been granted under PA 09/00034/A to redevelop the application site for residential purposes, with the application indicating that any such development would in all likelihood be in the form of apartments¹. This consent has now lapsed.

1. Planning approval has also been granted under PA 09/00982/B to develop the former site of the Ocean Castle Hotel, immediately to the north of the application site, with a scheme of apartments. The townhouses which have recently been constructed on the former site of the swimming pool and car park for the Port Erin Royal (to the south east of the main hotel) were approved under PA 13/00725/B, following the refusal of an earlier scheme which proposed to develop the site with 16 apartments (PA 09/01084/B).

Planning Policy Context

1. The planning policy context for the application is set out in the Isle of Man Strategic Plan (IoMSP) and in the Area Plan for the South (APS).

1. The Isle of Man Strategic Plan; the IoMSP was adopted by the Department in June 2007 and approved by Tynwald the following month, and is intended to provide "the strategic and general policy framework within which provision will be made for development and conservation needs for the period 2001-2016". Together with Area Plans the IoMSP forms a Development Plan as required by the 1999 Town and Country Planning Act. It is explained in the IoMSP that existing Local Plans will remain in effect until they are replaced by new Area Plans, and that the 1982 Development Plan, as amended by the various Local Plans, will have effect as an Area Plan. It is also made clear in the Plan that "in the case of any inconsistency between the provisions of the Strategic Plan and the provisions of an Area Plan,

¹ The approval notice for PA 09/00034 is attached at Appendix 1

whichever came into force later will prevail", with the APS being the most recent in this instance.

1. Amongst the Strategic Objectives of the Plan (pages 10-11) it is indicated that resources should be protected, used, and re-used in an efficient and economic way, that most new development should be guided towards existing settlements in order to make "the optimum use of existing and planned infrastructure and services", and that high quality development will be encouraged throughout the Island. It is also stated that the housing needs of the community should be met by the provision of sufficient housing of an acceptable standard and of an appropriate nature and in appropriate locations, and that high standards of residential amenity in new development and a physically safe environment will be promoted.

1. The Strategic Policies which flow from these objectives (pages 13-18) emphasize the need to make the best use of resources by, amongst other things, "ensuring efficient use of sites, taking into account the needs for access, landscaping, open space, and amenity standards" and "being located so as to utilise existing and planned infrastructure, facilities and services". New development will be located primarily within existing settlements or within sustainable urban extensions, and should be designed so as to make a positive contribution to the environment of the Island. Development proposals must also protect or enhance the fabric and setting of, amongst other things, Conservation Areas. In appropriate cases the Department will require planning applications to be supported by a design statement. The Plan makes it clear that "the provision of an adequate supply of housing to meet the needs of the wider community is essential", and that the housing needs of the Island will be met by making provision for the development of 6000 additional dwellings over the Plan period.

1. The IoMSP includes an Island Spatial Strategy (ISS, pages 19-27) which is intended to guide the physical development of the Island up to 2016. The Island is divided into North, South, East and West regions and the ISS seeks to "promote a balanced and equitable pattern of sustainable development across the Island". It is estimated that in order to meet the housing needs of the Island over the plan period provision will have to be made for the development of 6000 additional dwellings. The Plan indicates that the

archaeology. Environment Policy 36 (page 54) states that development which is outside of, but close to, the boundary of a Conservation Area will only be permitted where it will not detrimentally affect important views into and out of the Conservation Area. Environment Policy 42 (page 56) requires the design of new development in existing settlements to take account of "the particular character and identity, in terms of buildings and landscape features, of the immediate locality".

1. Housing Policy 1 (page 63) states that provision will be made for up to 6000 additional dwellings over the period of the Plan, which will be monitored and increased or decreased as necessary. Housing Policy 2 (page 63) states that the Department will seek to ensure the availability of land which is currently allocated for residential development in existing Local Plans, and goes on to suggest that designated land which is not brought forward for development within 5 years could be placed in a land-bank and alternative land allocated for development in its place. Housing Policy 3 (page 64) confirms the distribution of dwellings suggested by the ISS, and Housing Policy 4 (page 64) states that housing should primarily be located within existing settlements or within sustainable urban extensions. Housing Policy 5 (page 65) indicates that up to 25% of new dwellings on sites of 8 or more units will have to be affordable. Housing Policy 6 (page 66) states that residential development within areas which are zoned for such must be undertaken in accordance with an Area Plan development brief (should there be one) or otherwise in accordance with General Policy 2 of the IoMSP.

1. Recreation Policy 3 (page 87) states that, where appropriate, new development should incorporate landscaped amenity areas into the design and that new residential schemes of ten or more dwellings must make provision for recreation and amenity space in accordance with the standards specified at Appendix 6 of the Plan. The Plan makes it clear that the general standards of space provision set down for new residential development will be applied having regard to criteria such as the proximity and availability of existing Open Space, including the foreshore, public glens and parks, and school fields which may be available for use outside of school hours. Recreation Policy 4 (page 87) states that open space should be provided on site or conveniently close to the associated development.

Island's southern region – which is comprised of Castletown, Port Erin, Port St Mary and the Parishes of Arbory, Malew and Rushen – will accommodate 1300 of those dwellings, and the most recent Residential Land Availability report (published November 2013) indicates that there has been approval granted to 908 additional units in the South between 2001 and 2013. If projected conversions and windfalls for the period 2013-2016 are taken into account the total could reach 945 units, a shortfall of 355 from the IoMSP figure of 1300.

1. Spatial Policy 1 (page 24) identifies Port Erin as one of a number of Service Centres where development will be concentrated "to provide regeneration and choice of location for housing, employment and services". It goes on to state that 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 (page 25) states that new development will be located in the defined settlements, and that development will only be permitted in the countryside in accordance with General Policy 3.

1. General Policy 2 of the Plan (pages 30-31) identifies broad standards of development that should be taken into account if proposals are to be permitted, which include criteria in respect of building siting, layout, form and appearance, impact upon landscape or townscape, amenity standards for residents, highway safety and traffic flows, and parking space provision. Transport Policy 7 (page 97) requires parking provision in all new development to meet the Department's standards, which is shown at Appendix 7 of the IoMSP (page 135) to be 2 spaces for each 2 bedroom apartment. The supporting text (para A.7.1) indicates that in the case of town centre and redevelopment sites the Department will consider reducing the requirement having regard to a number of factors, including the location of the housing relative to public transport, employment, and public amenities. General Policy 3 (page 31) indicates that development will not be permitted outside of areas which are zoned for development unless it accords with one of the listed exceptions.

1. Policies in respect of the Built Environment provide guidance in respect of, amongst other things, Registered Buildings, Conservation Areas and

1. Appendix 6 of the Plan (pages 128-132) provides guidance in respect of open space requirements for new residential development, and confirms that the exact open space requirement will depend upon the individual circumstances and nature of each planning application. It goes on to differentiate between "open space" and "outdoor playing space", confirming that the latter may include sports and recreation facilities that are designed to serve the needs of either the general public or the members of a private organisation. It may also include formal or informal areas which are designed for children's play, but excludes areas such as woodlands and golf courses. The Plan sets the overall open space standard at 32 sq.m for each new resident, which is broken down further into 18 sq.m of formal space such as sports pitches, 6 sq.m of children's play space and 8 sq.m of amenity space. It also sets the assumed occupancy levels for new dwellings, and explains that where possible open space should be provided in the first instance on-site or off-site where this would improve the quality of the development and the open space provided. Where these options are not practical then commuted sums will be considered.

1. Transport Policies 1 and 2 (page 95) require new development to be located, where possible, close to existing public transport facilities and routes, including pedestrian, cycle and rail routes, and where appropriate to make provision for new routes including links into existing systems. Transport Policy 4 of the Plan (page 96) seeks to ensure that new and existing highways are capable of safely accommodating the vehicle and pedestrian journeys created by development, whilst Transport Policy 8 (page 97) requires all applications for major development to be accompanied by a Transport Assessment. The Plan recognises that development will be required in areas not yet connected to IRIS, and that interim drainage measures such as individual treatment works may be appropriate. Infrastructure Policy 1 (page 101) states that development shall only take place in areas that will ultimately be connected to IRIS, whilst Infrastructure Policy 2 (page 101) states that interim drainage arrangements for development in areas awaiting connection to IRIS shall be submitted to and approved by the Department. Energy Policy 5 (page 109) requires proposals

for more than 5 dwellings to be accompanied by an Energy Impact Assessment².

1. The Area Plan for the South; the Town and Country Planning (Area Plan for the South) Order 2012 was approved by Tynwald on 20ᵗʰ February, 2013 and came into operation on 1ˢᵗ March, 2013. As well as allocating specific uses to land in the South of the Island the APS provides Proposals and Recommendations which are intended to guide the development or protection of land and sites within the Plan area. Sites which are allocated in the APS for future development are referred to as “Proposal Sites”, and where appropriate they are the subject of a “Development Brief” which provides guidance on how a site should be developed and “an indication of the kind of development the Department would encourage and support”.

1. The APS provides a Spatial Vision for the South (page 14), the formulation of which was influenced by Isle of Man Landscape Character Assessment Report 2008. It includes a “Village Profile” for Port Erin, which recognises that “the top Promenade has been undergoing a steady process of renewal in recent years, including new apartments on the Promenade” and that “given the reduction in the demand for tourism accommodation in the Village many of the former hotels have been converted or redeveloped”. The accompanying “Summary of Area Plan Proposals” states that “Housing will be provided……by the continued conversion or redevelopment of redundant or under-used land and buildings within the settlement boundary (which may include former hotels)”.

1. It is pointed out in the Residential Development chapter of the APS (page 30) that the statistics included in the IoMSP indicate “a clear need to provide more residential properties on the Island in order to respond to these demographic changes and to provide for a range of house types and tenures”. Accordingly the APS, having had regard to factors such as residential land availability, urban capacity and the need for affordable housing, concludes that it is necessary to identify further residential sites to meet the needs of the South (page 34). The Plan identifies a number of “particular issues in the allocation of Residential land”, including affordable housing (page 35) and housing for an ageing population (page 38).

² An Energy Impact Assessment/Statement is attached at Appendix 2

1. It is also stated within the Residential Development chapter (page 39) that the number of units to be provided on individual Proposal Sites has not been specified within Development Briefs unless there is a valid planning reason for doing so. It goes on to state that SP1 of the IoMSP will be adhered to and to that end “the Department will ensure that a density level on the sites is realised which makes best use of the available land and seeks to optimise the number of dwellings on the site”, subject to material considerations.

1. The Port Erin Royal Hotel site is within an area which is identified as “Predominantly Residential” in the APS (Map 7). It is adjacent to, but not within, the part of Port Erin which the APS identifies as a Proposed Conservation Area (the designation of a Conservation Area is not part of the Area Plan process and must be done under the provisions of separate legislation). The site is not therefore subject to any of the constraints identified in Chapter 5 of the APS (The Natural Environment, the Built Environment and our Cultural and Historic Heritage) or the accompanying Constraints Map. These include, amongst other things, ASSIs, AEIs, Bird Areas and Ramsar Sites, areas subject to flooding or contamination, Conservation Areas, Ancient Monuments, sites of Archaeological interest and hazardous sites.

1. The section of the APS which considers Tourist Accommodation recognises that “Historically, much of the tourist accommodation was located in large seafront hotels in Port Erin and Port St Mary. The demand for this type of accommodation is now in decline and many of these large hotels have now closed allowing for redevelopment/conversion of the sites to take place where appropriate”. The Port Erin Royal Hotel is not identified at Tourism Proposal 1 as one of the hotels which, subject to viability, must be retained as such.

The Proposal

1. This application seeks detailed planning approval to replace the former Port Erin Royal Hotel with a new building containing 34 no. residential apartments and associated car parking. The principle of redeveloping the site for this purpose has previously been approved under PA 09/00034/A and is in accordance with the land use zoning of the Area Plan for the South.

1. It is proposed that the building will contain a mix of apartment sizes, and that the provision of affordable housing will form the subject of a S13 legal agreement between the applicant, the Planning Authority and the Department of Social Care.

1. The application is accompanied by a Design Statement which outlines how the scale, form, massing and detailing of the proposed building takes the context of the site into account, including the building which has been approved on the former Ocean Castle site immediately to the north.

1. The application is also accompanied by a Transport Assessment prepared by Bryan G Hall Consulting Civil & Transportation Planning Engineers, which concludes that the traffic likely to be generated by the application proposals can be safely accommodated on The Promenade without detriment to the convenience of other road users and hence that the proposals conform with the Policies and Guidance of the Area Plan for the South and the Isle of Man Strategic Plan and hence that planning approval should not be withheld for these reasons.

1. Vehicular access to (and exit from) the site will principally be from the Promenade into a basement car park, with further external parking accessed through the basement. There will in addition be 4 no. individual garages which face onto Rowany Villas. The lane which runs to the rear of Princess Towers, which is a public highway, will not be used for day-to-day vehicular access to the site but will have gates placed at its boundary with the application site so as to allow access in the case of emergency or other exceptional circumstances.

1. Each apartment will be served by at least one parking space with the larger units having two, resulting in a total of 45 no. parking spaces (including garages) to serve 34 no. units. The IoMSP indicates that in the case of town centre and redevelopment sites the Department will consider reducing the requirement having regard to a number of factors, including the location of the housing relative to public transport, employment, and public amenities. This is considered in the Transport Assessment and is an issue which was assessed at the appeal for PA 09/01984/B (16 no. 2-bed apartments on the hotel swimming pool site), and although the application was refused for reasons of

building size the Inspector raised no objection to the provision of 18 spaces to serve the development.

1. The IoMSP states that, where appropriate, new development should incorporate landscaped amenity areas into the design and that new residential schemes of ten or more dwellings must make provision for recreation and amenity space in accordance with the standards specified in the Plan. The Plan makes it clear that the general standards of space provision set down for new residential development will be applied having regard to criteria such as the proximity and availability of existing Open Space, including the foreshore, public glens and parks, and school fields which may be available for use outside of school hours. Whilst the provision of such space may be achievable when laying out a new housing estate it is often less practical to do so when re-developing the site of a single building with apartments, primarily due to the restricted site size, the relatively high number of units that can be provided in a taller building and the need to take streetscape into account. It is anticipated that an apartment development of the form proposed will not create significant demand for formal play facilities, and that the residents will be well served by the nearby Brooghs, Bradda Glen and Port Erin beach as well as the landscaped courtyard on site.