APL Statement

Planning Statement In Support Of The Demolition Of 6 And 8, Bridge Road And Associated Outbuildings, Douglas Im1 5Ag

Sarah Corlett Town Planning Consultancy Ltd 1 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 1.0 Introduction
• 1.1 6 and 8, Bridge Road are two conjoined buildings which front onto Bridge Road and which look east over Douglas Inner Harbour. Number 8 is semi-detached with a single vehicle width lane to the south which has double yellow lines along its length: number 6 is a mid terrace building with the Railway Hotel attached to the north.
• 1.2 The properties each have a small rear yard area with a currently open area to the rear of number 8 following the demolition of a former warehouse building. There is a further warehouse to the rear of number 6.

Sarah Corlett Town Planning Consultancy Ltd 2 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

1.3 The two properties appear very different from each other: number 6 is a three storey Victorian building with its front elevation featuring mouldings, string courses and cornice at first floor ground level and eaves level with a traditional chimney at each end and round headed windows on the ground floor. The windows are sliding sash although some are boarded up. The front door is centrally positioned and it too has a round headed with similar fanlight above the door. This building has a basement.

Sarah Corlett Town Planning Consultancy Ltd 3 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 1.4 Number 8 by contrast is much more modern with a double Roman heavy mansard roof, brick plinth above which is mock roughcast render work with horizontally proportioned plastic framed casement and fixed windows including three within the mansard level. Whilst this has three floors of accommodation, one is contained within the roof, leading to the building sitting lower than number 6 which in turn is slightly lower than the Railway Hotel.
• 1.5 The terrace is lower in height than the much more modern Quay West apartment block to the south of the lane.

Sarah Corlett Town Planning Consultancy Ltd 4 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

1.6 The layout of this part of Douglas in the 1860s was very different, with no through road to the south of the railway station and a row of buildings between the Railway Hotel and the station which no longer exist.

Sarah Corlett Town Planning Consultancy Ltd 5 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 2.0 Planning context Area Plan for the East
• 2.1 The site lies within an area designated on the Area Plan for the East which was adopted in 2020, as Mixed Use.
• 2.2 The pink line delineates the town centre boundary (the site falls within it) and the green shading denotes The Quayside area of Mixed Use for which there is a specific proposal and a number of references in the Written Statement although nothing that is considered relevant to the current application for the demolition of the existing buildings on the site.

Sarah Corlett Town Planning Consultancy Ltd 6 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 2.3 The Area Plan also includes Environmental and Infrastructural Constraints Maps. The former shows the Conservation Area in which the site lies and the latter (below left) shows the very rear of the site being within the 2016 Flood Risk Study Area. The Flood Hub maps show this a little more clearly (below right) and denotes the rear of number 6 being at risk of river and tidal flooding.

The Isle of Man Strategic Plan 2016

• 2.4 This sets out strategic policies which apply Island-wide. It acknowledges Douglas as the principal settlement which will remain the main employment and services centre for the Island (Spatial Policy 1).
• 2.5 There are policies which promote sustainable development within settlements and which minimise the reliance on the private motor car (Strategic Policies 1, 2 and 10, Spatial Policy 5 and Transport Policy 1).
• 2.6 There are policies which recommend high standards of design and finish and development which enhances the environment (Strategic Policies 3 and 5, General Policy 2 and Environment Policy 42).

Sarah Corlett Town Planning Consultancy Ltd 7 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 2.7 Development is presumed against which would result in harm to historic fabric and character (Strategic Policy 4).
• 2.8 Development is encouraged which makes the best use of sites (Strategic Policy 1).
• 2.9 The Strategic Plan and Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man both contain policies which protect the character and appearance of Conservation Areas and where development must either preserve or enhance the character or appearance thereof and take into account the special character of the CA in the determination of any application for development (Environment Policy 35 and CA/2).
• 2.10 In addition, the demolition of buildings which make a positive contribution to the CA is presumed against (Environment Policy 39 and Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man CA/6). The PPS also explains that “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.” The full wording of RB/6 is set out in Appendix One to this document.

Sarah Corlett Town Planning Consultancy Ltd 8 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 3.0 The proposal
• 3.1 Proposed is the demolition of all existing buildings on site. Included in the application are plans which demonstrate how the site could be redeveloped to demonstrate the acceptability of the removal of the buildings in that respect, by their replacement by two new buildings which provide Class 1 (shops) and/or Class 1.3 (consumption of food and drink on the premises) at ground floor level with seven apartments above. Full, detailed planning approval is being sought for this contemporaneously.
• 3.2 The new buildings have been designed to replicate what currently exists at number 6 and a continuation of this style in the new building in place of number 8 albeit slightly lower. The opportunity to expand the available floorspace for the commercial units has been taken by the addition of a single storey of flat roof at the rear, occupying the remainder of the site but leaving the rear private lane free for access.
• 3.3 No car parking is to be provided on the site.
• 3.4 Space for the storage of the refuse bins is provided at the rear with access thereto from the rear lane for collection.
• 3.5 The existing building at number 6 is in poor condition as is the warehouse building to the rear. There was a further warehouse between this and the lane - to the rear of number 8 which was demolished in 2022 due to its condition.
• 3.6 Structural surveys were undertaken of all three buildings in 2023 and are attached to this application. The warehouse, which is actually two conjoined buildings, showed signs of pronounced distortion in the roof of the three storey element, there was spalling evident on the north facing wall, a bow at first floor level in the elevation facing the lane and irregularities in the stone and brick face of the two storey wall facing the rear of number 6. Within the building steel beams displayed severe corrosion, timber beams showed decay and softening, support to the first floor joists did not appear robust. On the first and second floors the floor finishes exhibited pronounced sagging and did not feel secure underfoot with pronounced cracking to the walls with spalling finishes.
• 3.7 The conclusion of the report was that the building is in a very dilapidated condition and is not safe for occupation and in their view, the repairs would be uneconomic to undertake. It recommends demolition of the structure.

Sarah Corlett Town Planning Consultancy Ltd 9 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

3.8 The survey of number 6 was undertaken in July 2023 and revealed that the render face of the front wall to each side of the front entrance exhibited a lean of 100mm over a height of 3.6m above ground level with pronounced vertical cracking at the ground and first floor window reveals with cracking to the first floor string to the front wall.

Sarah Corlett Town Planning Consultancy Ltd 10 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 3.9 The timber lintel to the front wall exhibited decay and partial collapse. The timber lintel to the rear wall had collapsed. Internally the suspended timber floor finishes exhibited sagging and sloping and the front wall lintel was exposed with the wall and ceiling finishes exhibiting some spalling.
• 3.10 The conclusion was that the building is in a dangerous condition and whilst not in imminent danger of collapse onto public areas, the extent of deterioration and lean to the front wall will propagate further adverse movement, resulting in endangerment to the public. Structural measures to precent further adverse movement of the front wall will be difficult and hazardous to implement. The condition of the front wall and internal structure represents a significant health and safety risk and whilst external shoring could be theoretically introduced to restrain the front wall, such an arrangement impacts the footway and would be unlikely to be visually acceptable. If the front wall were restrained, the decayed timber lintels would need to be replaced, effectively requiring the rebuilding of the entire front wall. Rebuilding the front wall is feasible whilst shorting the remainder of the building but the poor condition of the remainder of the building would not structurally justify retention.
• 3.11 Their recommendation was to demolish the building with support and waterproofing provided to the adjoining buildings and infilling of the basement taking account of surcharging party walls. Prior to this, the movement of the front wall should be monitored pending demolition and in the event of further significant movement, an exclusion zone should be introduced to safeguard passers by.
• 3.12 The survey of number 8 was undertaken in July, 2023 and it was observed that there was vertical open joints and stepped and vertical cracking on the front elevation, sloping cills, distorted render and a lean in the rear wall with a pronounced slope inside toward Lake Road. The conclusion here was that the building exhibits significant adverse structural movement which may have arisen during the construction of Quay West apartments around

1. It recommended the inspection of the internal cavities to confirm the effectiveness of the wall ties and remediate if necessary and monitor movement of the external walls with inspection in 2 years time with further suitable remedial work if then required.

Sarah Corlett Town Planning Consultancy Ltd 11 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

Sarah Corlett Town Planning Consultancy Ltd 12 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 4.0 Planning history
• 4.1 Planning approval and Registered Building consent was sought for the demolition of the existing buildings on site and their replacement with new development on a number of occasions:

11/00422/CON was for the demolition of the existing buildings and was refused for the following reason:

1. Based on the fact there isn't an approved redevelopment scheme and the resulting visual impact from the proposed demolition on the streetscene and the Conservation area, it is considered the demolition of the buildings would be contrary to Policy CA/6 of Planning Policy Statement 1/01 and Environment Policies 35 and 39 of the Isle of Man Strategic Plan 2007. The Planning Authority considers the loss of the buildings to be unwarranted and would adversely affect the character and appearance of the Conservation Area.

A contemporaneous application, 11/00421/B for the replacement of the existing with a 12 apartment building was also refused for the following reasons:

• 1. The proposed development would, due to its height, design, massing and external appearance, introduce a prominent and incongruous development within the streetscene, be detrimental to the visual amenities of the locality and which would not preserve or enhance the character and appearance of the Conservation Area. The proposed development would therefore be contrary to General Policy 2 and Environment Policy 35 of the Isle of Man Strategic Plan 2007 and Planning Policy Statement 1/01.
• 2. Based on the fact that the redevelopment scheme is unacceptable, it is considered the demolition of the buildings would be contrary to Policy CA/6 of Planning Policy Statement 1/01 and Environment Policies 35 and 39 of the Isle of Man Strategic Plan 2007. The Planning Authority considers the loss of the buildings to be unwarranted and would adversely affect the character and appearance of the Conservation Area.

Sarah Corlett Town Planning Consultancy Ltd 13 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 3. The proposed development, due to its height, design and massing would result in demonstrable harm to the residential environment of the apartments of Quay West in terms of overlooking, loss of privacy, visual intrusion and being overbearing and would consequently be contrary to General Policy 2 and Housing Policy 6 of the Isle of Man Strategic Plan 2007.
• 4. The proposed development would, due to its design and internal layout, result in

• i. apartments 3, 6 and 9 having a poor residential environment by virtue of their outlook and lack of access to natural light;
• ii. apartments 7, 8 and 10 having a poor residential environment by virtue of dining area/lounge in apartment 10 being positioned above Bedrooms 1 and 2 of apartment 8; and a dining area/lounge in apartment 7 being positioned below the master bedroom of apartment 10, which would result in general disturbance and increased noise to the affected apartments.
• iii. apartment 3 having a poor residential environment by virtue of the terrace being overlooked from the above apartment's balconies.

The proposed development would therefore be contrary to General Policy 2 and Housing Policy 6 of the Isle of Man Strategic Plan 2007.

• 5. The proposed development is contrary to Housing Policy 5 and Paragraph 8.6.1 of the Isle of Man Strategic Plan 2007 in that the development would result in

• i. the loss of public sector housing, which would not be replaced as part of the redevelopment scheme, and;
• ii. no provision for affordable housing on the net increase of residential units on the site.

• 6. The proposed development would be contrary to Environment Policy 10 and 13 of the Isle of Man Strategic Plan 2007 in that the development poses an unacceptable risk from flooding and therefore should not be permitted until a detailed flood risk assessment along with details of any proposed mitigation

Sarah Corlett Town Planning Consultancy Ltd 14 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

measures are submitted in accordance with Environment Policy 10 of the Isle of Man Strategic Plan 2007.

1. The proposed development would be contrary to General Policy 2 (h) & (i) and Transport Policy 4 of the Isle of Man Strategic Plan in that adequate visibility cannot be achieved from the proposed access, which would be detrimental to highway safety.

09/0909/F and 09/00911/CON proposed the demolition of the existing outbuildings and was refused for the following reason:

The proposed demolition of the outbuildings would e contrary to Policy CA/6 of Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man and Environment Policies 35 and 39 of the Isle of Man Strategic Plan 2007 in that no proper assessment has been carried out to assess the merits/justification for the demolition of the existing building. It is considered that the demolition of the existing outbuildings would adversely affect the character and appearance of the Conservation Area.

4.2 Other applications on the site include the following:

93/00497/B - replacement of windows on front elevation, 6, Bridge Road - permitted

• 07/02320/B - conversion of ground floor and first floor from residential to restaurant and wine bar, 7, Bridge Road - permitted
• 07/02321/B - conversion of residential to office use, 6, Bridge Road - permitted

Sarah Corlett Town Planning Consultancy Ltd 15 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

• 5.0 Assessment
• 5.1 There is no Conservation Area Character Appraisal for the North Quay CA. However, the site is clearly within it and number 6 is an old building which retains much of its original detailing and interest. There is therefore, a presumption in favour of the retention of this building.
• 5.2 The warehouse to the rear does not appear to be as old as number 6 but is nevertheless interesting due to its age.
• 5.3 The building at number 8 is much more modern and, we would submit, is an incongruous building within this street scene and which does not contribute positively to the character and appearance of the CA. Its removal should, therefore, not be considered contrary to Environment Policy 39 and CA/6 without any need for further justification. In fact, we would argue that the removal of this building would provide an opportunity for the introduction of a building which is much more sympathetic to its context and the attached detailed scheme for a replication of the building on number 6, for which detailed planing approval is being sought, demonstrates this.
• 5.4 The warehouse and number 6 are, however in very poor repair, through no fault of the applicant who purchased the site only recently. The Structural Engineer’s reports for the buildings demonstrate the condition of these buildings together with information about what would be involved in any scheme to try to retain the front facade, which would effectively be rebuilt, taking into account the amount of fabric which would need to be replaced to make the building structurally acceptable. The replacement building would satisfy the flood risk criteria by being above the maximum tidal and river flood level and would not have a basement, which the current property does have. The risk to the building from flooding would be considerably reduced as a result.
• 5.5 The detailed plans and accompanying planning application demonstrate that the existing building at number 6 could be replicated, ensuring the continued positive contribution to the Conservation Area and enhanced by the removal of the existing building at number 8 and its replacement with something more sympathetic to number 6 and the otherwise traditional character of the rest of the terrace.
• 5.6 Whilst there is no parking provided (which is more a matter for the planning application not this application for Registered Building Consent), it was resolved that the creation of car

Sarah Corlett Town Planning Consultancy Ltd 16 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

parking within the site (where there was none previously with the current parking provision being as a result of the demolition of the former warehouse on the site) would not preserve or enhance the character of the Conservation Area and that, as had been the case previously, the rear of the buildings should be occupied by buildings, not an open hard surfaced area which would not contribute positively to the character or appearance of the Area.

• 5.7 In summary, we would submit that the demolition and replacement of number 8 should be considered acceptable as this property does not currently contribute positively to the character or appearance of the Conservation Area, and its removal would therefore not contravene Environment Policies 35, 39 or RB/6 and CA/6 of the Planning Policy Statement 1/01.
• 5.8 Whilst number 6 has historic interest due to its age as has the warehouse to the rear, their condition, described in the Structural reports attached to this applicant, demonstrate that neither building is in a condition which would enable their retention to be practical or economically viable, with any restoration or even stabilisation or safety works having a detrimental impact on the character and appearance of the area and the safety and convenience of those passing the site. The practicality and viability of retaining structurally deficient buildings are matters which may be considered, as described in RB/6.
• 5.9 We would submit that the demolition and replacement of number 6 and the warehouse to the rear should be considered to be acceptable and in accordance with the requirement for development to preserve or enhance the character or appearance of a Conservation Area (EP35 and CA/2).

Sarah Corlett 27.01.24

Sarah Corlett Town Planning Consultancy Ltd 17 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

Appendix One

EXCERPT FROM Planning Policy Statement 1/01 - 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:-

In judging the effect of any proposed alteration or extension to a Registered Building, it is essential to have assessed the elements that make up the special interest of the building in question. They may comprise not only obvious features such as a decorative facade, or an internal staircase or plaster ceiling, but may include the spaces and layout of the building and the archaeological or technological interest of the surviving structure and surfaces. These elements can be just as important in the simple vernacular and functional buildings, as in grander status buildings. Cumulative changes reflecting the history of use and ownership can themselves present an aspect of the special interest of some buildings, and the merit of some new alterations or additions, especially where they are generated within a secure and committed long-term ownership, are not discounted.

The destruction of historic buildings is in fact very seldom necessary for reasons of good planning: more often it is the result of neglect, or failure to make imaginative efforts to find new uses or incorporate them into new developments.

• The condition of the building, the cost of repairing and maintaining it in relation to its importance and to the value derived from its continued use. Any such assessment should be based on consistent and long term assumptions. Less favourable levels of rents and yields cannot automatically be assumed for

Sarah Corlett Town Planning Consultancy Ltd 18 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C

historic buildings and returns may, in fact, be more favourable given the publicly acknowledged status of the building. Furthermore, historic buildings may offer proven performance, physical attractiveness and functional spaces, that in an age of rapid change, may outlast the short-lived and inflexible technical specifications that have sometimes shaped new developments. Any assessment should take into account possible tax allowances and exemptions. In rare cases where it is clear that a building has been deliberately neglected in the hope of obtaining consent for demolition, less weight should be given to the costs of repair;

• • The adequacy of efforts made to retain the building in use. An applicant must show that real efforts have been made, without success, to continue the present use, or to find new uses for the building. This may include the offer of the unrestricted freehold of the building on the open market at a realistic price reflecting the building’s condition.
• • The merits of alternative proposals for the site. Subjective claims for the architectural merits of a replacement building should not justify the demolition of a registered building. There may be very exceptional cases where the proposed works would bring substantial benefits for the community; these would have to be weighed against preservation. Even here, it will often be feasible to incorporate registered buildings within new development, and this option should be carefully considered. The challenge presented by retaining registered buildings can be a stimulus to imaginative new designs to accommodate them.

Sarah Corlett Town Planning Consultancy Ltd 19 Registered address: Ballachrink Croft, Ballacorey Road, Bride, Isle of Man IM7 4AW t: 07624 485517 e: [email protected] w: www.sarahcorlett.com Directors: Sarah Elizabeth Corlett Nicola Jane Corlett

Company Registration 134325C