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Application No.: 16/01252/B Applicant: IOM Government Department Of Health & Social Care Proposal: A multi use, social care development for adults with learning difficulties, consisting of a day care facility with management offices; industrial training facility (ERIC Unit); horticultural training facility; cafe and retail unit. Site Address: Proposed Eastcliffe Healthcare Facility Old Ballamona Farmhouse Complex Strang Douglas Isle Of Man Case Officer : Mr Edmond Riley Photo Taken: 23.11.2016 Site Visit: 23.11.2016 Expected Decision Level: Planning Committee
THIS APPLICATION IS BROUGHT BEFORE THE PLANNING COMMITTEE OWING TO THE SCALE AND NATURE OF THE PROPOSAL AND ALSO BECAUSE IT MAY BE CONSIDERED CONTRARY TO THE DEVELOPMENT PLAN BUT IS RECOMMENDED FOR APPROVAL.
1.0 THE APPLICATION SITE - 1.1 The application site is an irregularly shaped parcel of land bounded to the northwest by Ballaoates Road, to the southwest by a single residential dwelling ('Harold Cottage') and also by the land the subject of the recent planning approval for a new office for Braddan Commissioners and associated healthcare and leisure uses, and to all other compass points by land and buildings associated with Noble's Hospital. - 1.2 Within the site are a number of buildings and land uses, which historically comprised the Department of Health and Social Care's (DHSC) estate offices and workshops, along with grounds maintenance buildings as well as the Eastcliffe Resource Industrial Centre (ERIC), which is a 'social firm' designed to provide work-based activities for adults with learning difficulties. - 1.3 The most attractive of the buildings on the site is the Ballamona Farmhouse, which until recently provided office space for the DHSC's estate management team. Government recently moved to a 'centralised' estates function across all Departments, located in Peregrine House in Douglas, and some of the resulting vacant office space within the Farmhouse is temporarily occupied by some hospital support services. - 1.4 The Farmhouse is unusual in shape and form and has clearly been much-altered since its original construction at least 150 years ago, with the most striking element being the prominently hipped roof on the maintenance store. Indeed, it is clearly formed of at least two but perhaps as many as six separate elements of historic fabric that have been joined together or form extensions. - 1.5 The other buildings within the site are much more utilitarian in appearance in a manner that reflects the associated uses described above. Perhaps of most historic interest is an older, twostorey warehouse building. This has at some point been re-roofed with a zinc finish and the building appears to be of blockwork construction. There is nothing to indicate it requires any
2.0 THE PROPOSAL - 2.1 Full planning approval is sought for the redevelopment of the site as an adult learning facility with associated uses. The applicant is the DHSC. The four main components of the scheme are set out in a Design Statement with the application. Although the site is intended to be operated as a single entity, for ease of reference the four main components are set out below. An Adult Day Service
2.6 The shop, café (and associated kitchen) and garden centre would be staffed largely by the intended service users of the Eastcliffe site - that is, adults with learning difficulties. - 2.7 As outlined previously, although there are four distinct elements to the proposal they are all intended to be operated in conjunction with one another - and also by the DHSC, much as the existing uses are already elsewhere on the Island. Along with the Design Statement, the application has been submitted with a 'Planning Statement Relating to Drainage' and also a Landscape Masterplan for the site. The Masterplan contains useful information regarding the kind of species of trees, shrubs and hedging plants intended for the site but does not contain - for example - a planting specification. Accordingly, the Masterplan itself would not be specific or detailed enough to be enforceable and, should the application be approved, a condition seeking further details on this would probably be well-advised. - 2.8 Some 79 car parking spaces are proposed across the site, plus another seven minibus / tipper van spaces, which also double up to provide 14 visitor / drop-off spaces to cater for visitors to the site. The Design Statement includes a Transport Statement that outlines the parking requirements, which is judged to be 65 overall (28 for the Day Centre, 13 for the café / shop, nine for the ERIC Unit, and six for the Garden Centre, plus another nine parking spaces for the offices on the Farmhouse). - 2.9 Parking for people with disabilities is spread throughout the site and all spaces are accessible via graded footpaths without steps. - 2.10 An amended Proposed Site Plan that showed additional footpaths within the site was received following negotiation with Highway Services (see paragraph 5.1, below). This was circulated to the interested parties.
3.0 RELEVANT PLANNING HISTORY - 3.1 The site has been the subject of a number of applications over the years; none has been submitted since the adoption of the Strategic Plan in 2007, but a number were submitted following the adoption of the Town and Country Planning (Permitted Development) (Government Owned Land) Order 2012. None is considered to be specifically material to the assessment of this application, but it is worth noting them as they help indicate the evolution of the site from a farm and a hospital into the current uses operating from the site.
3.2 The Planning Committee may recall having approved PA 16/00601/B, which was for the "erection of a multipurpose Community Centre incorporating Braddan Commissioners offices / headquarters with associated car parking and landscaping". That application was, coincidentally, submitted by the same architectural team as the application now before the Committee, and hence there are some design parallels between the two schemes.
4.0 THE DEVELOPMENT PLAN AND RELEVANT LEGISLATION - 4.1 The site would appear to fall within an area zoned as 'Ballamona Hospital' on the Braddan Local Plan, which was adopted in 1991. Accompanying this designation is a recommendation within the Braddan Local Plan Written Statement that a long-term strategy for the Hospital be prepared. This has evidently been overtaken somewhat by events, and there has even been the grant of permitted development rights for the wider Noble's Hospital Site, the accompanying text for which reads in full as follows:
"Operations within the area shown by a thick black line on the map attached to this Schedule consisting of the following classes of development —
4.2 No trees are to be felled as part of the application, while the end-user is the DHSC. However, while some of the buildings proposed in respect of this application may be considered as being 'incidental' to the use of the wider site as a hospital, not all are - and even then such a conclusion would not unreasonably be subject to scrutiny. It was therefore concluded that a full application for the entirety of the works should be submitted such that they could all be assessed together and consideration of the relationship between the uses made. - 4.3 In view of the above, it is considered appropriate to assess the application against General Policy 2 of the Strategic Plan, which sets out general criteria to be met in applications seeking approval for development on land zoned for that specific kind of development. Strategic Policies 3 and 5, Community Policies 2 and 3, Environment Policies 17, 18 and 42, Business Policy 10 and Transport Policies 6 and 7 also provide important assessment points. - 4.4 General Policy 2 reads, in part, as follows: "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:
4.5 Environment Policy 17: "The development of buildings and other facilities associated with nurseries and market gardens will only be permitted where:
4.6 Environment Policy 18: "Retailing from farms, market gardens and nurseries (excepting ancillary sales of produce grown thereon) will be subject to the Department's general retail policies." - 4.7 It is also worth noting the paragraphs supporting Environment Policies 17 and 18:
4.8 Environment Policy 42 reads: "New development in existing settlements must be designed to take account of the particular character and identity, in terms of buildings and landscape features of the immediate locality. Inappropriate backland development, and the removal of open or green spaces which contribute to the visual amenity and sense of place of a particular area will not be permitted. Those open or green spaces which are to be preserved will be identified in Area Plans." - 4.9 Community Policy 2 reads: "New community facilities should be located to serve the local population and be accessible to non-car users, and should where possible re-use existing vacant or underused buildings." - 4.10 Community Policy 3 reads: "Development (including the change of use of existing premises) which results in the loss of a local community facility (other than shops and public houses) will only
4.14 Strategic Policy 5 reads: "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." - 4.15 Business Policy 10 reads: "Retail development will be permitted only in established town and village centres, with the exceptions of neighbourhood shops in large residential areas and those instances identified in Business Policy 5." (Business Policy 5 refers to only land zoned for industrial uses, and therefore does not apply here.) - 4.16 Transport Policy 8 requires that applications for major development require the submission of a Transport Assessment; the matters required to be covered in a TA are considered to be covered in the Traffic Statement submitted with the application. - 4.17 Unlike the recently approved Braddan Commissioners Offices, the kind of development proposed here is not specified in Appendix 5 of the Strategic Plan as being one that would ordinarily require the submission of an Environmental Impact Assessment (EIA). No EIA has therefore been sought.
5.0 CONSULTATIONS AND REPRESENTATIONS - 5.1 Highway Services of the Department of Infrastructure engaged in negotiation with the agent to the application to address what was judged to be a lack of connectivity within the scheme and also relative to the surrounding land / buildings. On 24th January 2017, commenting on the amended plans described above but which had yet to be received and circulated by this Department, they offered no objection to the application as follows:
"The proposal is to relocate several facilities that are located within Douglas to a single site within the Nobles Hospital site, access will be via the Nobles Hospital internal road network.
"The facilities are primarily for the care of adults with complex needs and will be provided in 3 main buildings with a garden centre and greenhouses. There will be sufficient maneouvring space for service vehicles and adequate car parking for staff and visitors to the site. Many if the service users are provided with transport to and from the site, some are dropped off/picked up by carers and some may use public transport.
"The location for the complex has been chosen in part to allow the service users easy access to the other facilities provided on the Nobles Hospital site.
"The submitted plans do not indicate adequate pedestrian provision either through the site, linking the buildings or between the site and the adjacent hospital facilities. Safe pedestrian links are
particularly important for this application due to the requirements of the service users who may have specific needs with regard to mobility.
"Following discussions with the architect and project manager an amended scheme has been agreed and will be submitted to the planning authority. Highway Services does not oppose this application subject to the approval by the planning authority of an amended pedestrian provision."
5.2 The Arboricultural Officer of the Department of Environment, Food & Agriculture was contacted for his views. On 9th December 2016, he confirmed no objection to the application but sought a condition as follows:
"No development shall commence until a tree planting specification, in accordance with the recommendations of BS8545:2014, has been submitted to and approved in writing by the Planning Authority. The tree planting and post planting maintenance shall be carried out as approved. If, within 5 years of planting, any of the trees is cut down, uprooted, removed, destroyed or dies or becomes, in the opinion of the Planning Authority, seriously damaged or defective, another tree of the same species shall be planted at the same location."
5.3 The Drainage and Flooding officers within Manx Utilities were contacted for their views. They advised on 6th December 2016 that, "the applicant is required to submit full details of the drainage layout prior to the commencement of works". As layouts of the foul and surface water drainage were submitted with the application, it is concluded that the 'full details' sought by the MU relate to engineering matters and which can be addressed via the addition of an appropriate planning condition to the decision notice should the application be approved. - 5.4 Braddan Parish Commissioners offered no objection to the application on 30th November 2016.
6.0 ASSESSMENT - 6.1 Although the proposed development might not comply with the strict conditions as set out in the Permitted Development Order with respect to government-owned land, it is considered that the majority of the uses proposed within the application do comply with the Local Plan zoning for the site and moreover reflect the existing use to no small degree. With a scheme as varied as this, however, it is perhaps unsurprising to find certain elements - notably the café, shop and garden centre - are not in compliance with the zoning for the site and, moreover, could be said to conflict with some of the policies of the Strategic Plan. It is with this in mind that it is helpful to be in a position to assess the proposed buildings and uses as an holistic, rather than piecemeal, exercise. - 6.2 It is considered that the key issues are (a) whether or not the principle of the uses proposed is acceptable, (b) whether or not the design of the buildings is acceptable, both in terms of their physical appearance and also their effect on neighbouring uses, (c) whether or not the effect on highway safety in the area is acceptable, (d) whether or not drainage and flood risk has been adequately addressed and, finally, (e) whether or not the landscaping masterplan is acceptable. Each is addressed in turn. Whether or not the principle of the uses proposed is acceptable - 6.3 As noted above, the majority of the uses proposed are considered to comply with the site's zoning on the Braddan Local Plan, even if to reach this conclusion quite a wide reading of the definition of 'Hospital' is needed. While to many people there will not be a clear symmetry between a Hospital and 'healthcare', there is perhaps a clearer link between the provision of services and facilities for adults with learning difficulties and healthcare. The predominant element of the development proposal, which is considered to be the ERIC Social Firm, already operates from the site.
6.4 The day centre, while not currently operating from the site, is an existing use elsewhere on the Island and, it is understood, has many of the same end-users as does ERIC. There is clear synergy between these two uses. Moreover, it should not be ignored that the entirety of the site will be administered by the DHSC, which is the applicant and landowner. - 6.5 It is therefore concluded that the principle of the ERIC Social Firm and Adult Day Centre, without necessarily wholly in compliance with the land use zoning, is nevertheless linked to such uses. That the DHSC have confirmed that this land is not required by or for Noble's Hospital gives further reason to conclude that these two uses are, in principle, acceptable for this location. This latter point is an important one. The Planning Directorate needs to be assured that the approval of this application will not result in near-future applications for buildings outside of the land zoned for Hospital use because there is no longer sufficient available land. With this in mind, the DHSC and the agent to the application were contacted. - 6.6 The architect offered the following comments in respect of the need for the existing land to be retained for specifically Hospital-related uses:
"As the site has been used for many years as a support function for the Nobles Hospital Estate, and for the last 16 years as the DHSC Estates offices, stores and workshops, the area of land has not been part of the patient care provision portfolio, with the exception of the area in which the ERIC Unit has been sited here and operating for the last decade or so. The proposed uses are more closely related to health facilities, particularly as the thrust of the scheme is to bring adults with learning difficulties into a location which makes it simpler to provide such adults with the support they need in accessing more acute and primary healthcare facilities. The location of the site on the fringe of the acute hospital site, and adjacent to the largest GP surgery on the Island, and the Dental, Pharmacy & Optician's facilities to be provided by the adjacent Braddan Community Development, will allow the DHSC to provide a significantly better healthcare outcome to adults with learning difficulties, who as outlined in Mr Carey's document, have significantly lower outcomes in seeking and obtaining healthcare support, and therefore suffer worse health as a result. The argument could therefore be made that there is an underlying healthcare benefit in outcomes for adults with learning difficulties, and therefore the scheme has as much to do with health provision as social care, which therefore warrants the use of the site for such purposes."
6.7 The Operational Lead (Adult Social Care) within the DHSC provided a helpful document explaining the basis of, and need for, the proposed development. The relevant points are set out below:
"Significant improvements have been made in services for people with learning disabilities, with more people now leading full and rewarding lives. Over the lifetime of the first Learning Disability Strategy, significant improvements were made, with increased opportunities for people to choose how and where they live and how they spend their days. The second Learning Disability Strategy [launched in 2014] is about how we can improve things even further with a stronger focus on four key themes, housing, employment, health and inclusion."
"The majority of Day Services are currently provided at Eastcliffe Resource Centre. Eastcliffe was originally a large family home constructed over 100 years ago… Over the years the evolution of Day Services has resulted in a variety of extensions and adaptations that now make it virtually impossible to make any further significant changes.
"The model of provision for Day Services has also changed over time and strategically the focus is now on providing meaningful day time activity that encompasses a greater focus on employment opportunities. Importantly a model of employment for service users is currently provided on the proposed site at the former Ballamona Farm (ERIC Unit).
"Day Services for adults with a learning disability are currently provided across four main sites, Eastcliffe Resource Centre, Greenfield Garden Centre, Eastcliffe Resource Industrial Centre (ERIC)
and Mooragh View in Ramsey. This planning application sets out proposals to replace Eastcliffe and together move Greenfield Garden Centre and ERIC onto the one site. The economies of scale in bringing together the "Day Centre" and two work sites into the one area which will enable a more efficient use of staffing resources.
"There are presently no suitable facilities at the Eastcliffe building which means it does not comply with the Regulation of Care Act 2013. The land currently proposed for this development is owned by the Department of Health and Social Care and therefore developing Day Services on this site will ensure we provide quality and value for money for the tax payer of the Isle of Man.
"A number of site options were considered for this development and for a variety of reasons, including risk, all of the sites have been determined as being unsuitable.
"While Adult Social Care initially favoured redevelopment on a green field site the Department of Health and Social Care has approved the use of the former Estates complex buildings and site area for the development of this capital scheme. The tangible benefits in the use of this particular land are:
"What is abundantly clear is that parents and carers want services that meet the needs of service users, irrespective of who provides them. It is the quality of the service that is of paramount importance. We believe that a modern, flexible and diverse range of Day Services will improve the options available to adults with Learning Disabilities.
"Existing Day Services have been in place for a considerable time and have seen a significant improvement in the quality of life for those people who access the Departments services. Fundamental to the development of those services is ensuring that they are delivered in buildings that are both fit for purpose and compliant with the standards laid out in the Regulation of Care Act."
6.8 Collectively, these comments are extremely helpful and comforting. While it remains somewhat unclear as to whether or not the strategic needs of Noble's Hospital have been considered in coming to this conclusion, the application proposals nevertheless reflect a defined need within a strategic assessment of a particular element of care provision. - 6.9 There are, however, other matters for consideration: namely whether or not the café, shop and garden centre are acceptable here. - 6.10 In respect of the first question, it is noted that the architect has been at pains to stress the 'not-for-profit' nature of the shop, garden centre and café. Each of these represents a different Use Class, and the former and latter are uses are certainly those that would normally be directed towards existing town / retail centres, and therefore fall to be assessed against Business Policy 10.
Whether or not the landscaping masterplan is acceptable
6.27 The comments from the Arboricultural Officer are noted and as a whole the scheme will be subject to what is judged to be a well-considered landscaping strategy. The Hospital is set within very green and heavily treed grounds and this scheme will complement that existing character. The condition requested by the Arboricultural Officer seems reasonable in the circumstances given that there are a number of existing trees on or nearby the site and proper consideration needs to be given as to the most appropriate way forward for the site that reflects its surroundings, even if there is a good level of detail already provided within the application. Conditions should be used where necessary and where surety is required, which is considered to be the case here. Other matters - 6.28 There will be additional members of the public visiting the site should the proposed uses go ahead. This should not be ignored, and nor should it be ignored that this will also change the nature and character of a site that has historically been in healthcare use and largely, therefore, closed to visiting members of the public. That said, the scale and nature of the uses proposed is acceptable and, indeed, could be judged an appropriate consolidation of a particular healthcare into a single location on the Island. There is unlikely to be a significant footfall arising from the commercial uses proposed (such as they are even commercial in the sense that most people might take it to be), and so there is unlikely to be a particularly harmful impact that this would bring to the wider area. - 6.29 It is to be remembered that the applicant is the administrator of Noble's Hospital. - 6.30 That the scheme will also tie in with the approved Commissioners' Offices is noted and welcomed.
7.0 CONCLUSIONS AND RECOMMENDATION - 7.1 Overall, the development proposed reflects a specific and defined requirement that is best met on a site within the ownership of the Department that will be administering it. The various uses reflect best practice in terms of services for adults with learning difficulties and while some concern regarding the loss of some land from hospital use is reasonable it is also to be remembered that the site is already somewhat outwith 'traditional' hospital uses. The buildings proposed would sit well within their context, with or without the adjacent Braddan Commissioners building being developed, and the green setting of the site would be protected via the landscaping scheme and condition recommended. - 7.2 Perhaps the most significant concern is the café, shop and garden centre proposed as part of the scheme. These are, if operated on a commercial basis independently from the hospital estate, quite likely to be judged an inappropriate land use on land that has been specifically set aside for healthcare purposes. However, a reasonable conclusion must be that these three uses are integrally linked to the adult care facilities that would be the fundamental use of the site, not least since the land is owned by the Department of Health and Social Care. It is explicit within the application that the café and retail shop are intended as much as training facilities as commercial operations, while there is also an implicitness that this would be the case with the garden centre as well. As discussed earlier, it would be reasonable to require that any approval issued shall enure for the sole benefit of the applicant. - 7.3 It is therefore concluded that the application complies with the relevant Development Plan policies, is acceptable, and is accordingly recommended for approval subject to conditions.
8.0 INTERESTED PERSON STATUS - 8.1 By virtue of the Town and Country Planning (Development Procedure) (No 2) Order 2013, the following persons are automatically interested persons:
Recommendation Recommended Decision: Permitted Date of Recommendation: 20.02.2017 Conditions and Notes for Approval: C : Conditions for approval N : Notes attached to conditions
Reason: To comply with article 14 of the Town and Country Planning (Development Procedure) (No2) Order 2013 and to avoid the accumulation of unimplemented planning approvals.
Reason: The development hereby approved is only acceptable in this location because of the specific nature of the applicant as a service provider for healthcare.
Authority, seriously damaged or defective, another tree of the same species shall be planted at the same location
Reason: In the interest of protecting the green setting of the application site.
The development hereby approved relates to Drawings P/10-01, P/10-02, P/10-102, P/10-103, P/10104, P/10-105, P10-202, P10-203, P10-302, P10-402, P10-403, P10-404, P10-405, P10-406, P10407, P11-101, P12-101, P12-201, P12-301, P12-302, P10-303, P10-304, PL414/01, 16-080 11, 16080 12, 16-080 13, 16-080 14 and 16-080 501 (all dated as having been received 4th November 2016), and also to Drawing P/10-101 Rev A (dated as having been received 7th February 2017, and also to the Design statement (dated as having been received 4th November 2016).
I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to it under the appropriate delegated authority.
Decision Made : Permitted Committee Meeting Date: 06.03.2017
Signed : E RILEY 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
Application No. : 16/01252/B Applicant : IOM Government Department Of Health & Social Care Proposal : A multi use, social care development for adults with learning
difficulties, consisting of a day care facility with management offices; industrial training facility (ERIC Unit); horticultural training facility; cafe and retail unit.
Site Address : Proposed Eastcliffe Healthcare Facility Old Ballamona Farmhouse Complex Strang Douglas Isle Of Man
Presenting Officer : Mr Edmond Riley (correct manually if not the case officer)
The Planning Committee noted correspondence from the architect that had been received by the Department the morning of the Committee's meeting, which set out that the drainage details were already progressing through Building Control. The recommended Condition 4 was therefore redundant as the reason for its addition had since been overtaken by other events. It was therefore agreed that this condition should not be attached to the decision notice.
Reason: To comply with article 14 of the Town and Country Planning (Development Procedure) (No2) Order 2013 and to avoid the accumulation of unimplemented planning approvals.
Reason: The development hereby approved is only acceptable in this location because of the specific nature of the applicant as a service provider for healthcare.
Reason: In the interest of protecting the green setting of the application site.
The development hereby approved relates to Drawings P/10-01, P/10-02, P/10-102, P/10-103, P/10104, P/10-105, P10-202, P10-203, P10-302, P10-402, P10-403, P10-404, P10-405, P10-406, P10407, P11-101, P12-101, P12-201, P12-301, P12-302, P10-303, P10-304, PL414/01, 16-080 11, 16080 12, 16-080 13, 16-080 14 and 16-080 501 (all dated as having been received 4th November 2016), and also to Drawing P/10-101 Rev A (dated as having been received 7th February 2017, and also to the Design statement (dated as having been received 4th November 2016).
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