APL Planning Statement

Planning Statement In Support Of The Installation Of A Digital Advertising Screen, Looky’S Bar, Palace Hotel And Casino, Central Promenade, Douglas Im2 4Na

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 The site
• 1.1 The site is the curtilage of the Palace Hotel, currently the Best Western Palace Hotel which also incorporates the Paragon Restaurant, gym and spa suite, casino, Majestic Restaurant and Kursaal Bingo lounge. The site lies on Central Promenade in Douglas with the Palace Cinema lying to the west at a higher level; a row of shops - the Castle Mona Shops - beneath the Castle Mona Hotel to the south west; to the north west is Palace Road, somewhat higher than the application site and to the north east is Palace View Terrace onto which front the Palace View Apartments and the side of Queen’s Mansions.
• 1.2 The building on the site is relatively modern compared with the majority of the promenade in which it sits. The site originally accommodated a significant ballroom in 1887 which was damaged by fire in 1902 and was rebuilt only to be burned down again in 1920 and again, rebuilt. The Coliseum building which originally sat in front of the Palace Lido/ ballroom, was demolished in 1965 to make way for the building which generally appears on the site today. The ballroom claimed to be one of, if not the largest in Europe and was demolished in the 1990s and occupied what is now the cinema and upper level car park.

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 building on site today is a long, flat roofed structure with significant amounts of glazing on its frontage with a more functional elevation to the rear, brightened by the entrance at the northern end of the car park. The frontage has a horizontal emphasis broken into sections which have different glazing treatments with the Kursaal having projecting ground floor bays, the Cushag Suite function room having square bars at first floor level, the Paragon Restaurant having a striking blue facade and the Shearwater Suite function room having a projecting section which steps forward of the rest of the frontage and with recessed windows and a white horizontal fascia above.
• 1.4 The application concerns a small part of the overall building - the south western side of the projecting section on the north eastern end of the building. This currently displays a fixed sign announcing “Best Western Palace Hotel & Casino” with the BW logo. This was permitted as part of a range of rebranding signage under 17/01313/D (see Planning History).

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

• 2.0 Planning policy
• 2.1 The site lies within an area of Mixed Use on the Area Plan for the East which was adopted in 2020. There are no Community or Infrastructural Constraints marked on the maps accompanying the Plan and the only Environmental Constraint is the Conservation Area in which the site lies (see later).
• 2.2 There are no Registered Buildings within the site although the neighbouring Castle Mona Hotel is on the Protected Buildings Register (RB 82).
• 2.3 The site is not shown as being at risk of flooding on the national flood risk maps although there is an area of the rear car park showing as experiencing surface water pooling.
• 2.4 The Conservation Area (CA) in which the site lies is the Promenades CA which stretches from the Manx Electric Railway sheds in the north east to the Sea Terminal Building in the south west. The Conservation Area Appraisal refers to both the Castle Mona Hotel and the Palace Hotel as being on Queen’s Promenade and makes the following comments about the site:

Although hailed as true ground-breaking architecture when it was first constructed in the 1960s, the present modern appearance of the Hilton Hotel unfortunately jars the rhythm and line of the majority of buildings which make up the curve of the sea frontage of Douglas.

• 2.5 Development which accords with the land use designation is expected to respect the criteria set out in General Policy 2 of the Strategic Plan and development is generally expected to have a positive visual impact on the environment (Strategic Policies 3, 4 and 5 and Environment Policy 42).
• 2.6 Development within Conservation Areas is expected to preserve or enhance the character or appearance of the Area in accordance with Environment Policy 35 and Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man which also requires that the special characteristics of the Area are taken into account in the determination of any planning application.

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

• 2.7 Whilst the application building is not Registered, the adjacent Castle Mona Hotel is, as is the Falcon Cliff former hotel on the top of the cliff above, and the Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man and Strategic Policy 4 are clear that developments which adversely affect a Registered Building shall not be permitted (RB/5).
• 2.8 The Town and Country Planning (Control of Advertisements) Regulations 2013 set out the provisions for the control of any advertising material. Part 1 of the Regulations describes a range of advertisements which may be displayed anywhere on the Island without the need for permission. This is a limited range of advertisement types which would not allow the installation of any signage on a building other than that which is incorporated into the fabric of the building itself. Part 2 sets out a much wider range of permitted or “deemed” consent but this is not applicable within any Conservation Area. In any case, such adverts may not be illuminated.
• 2.9 The Regulations make it clear that:

(1) The Department must exercise its powers under these Regulations only in the interests of amenity and public safety, taking account of any material factors, and in particular —

• (a) in the case of amenity, the general characteristics of the locality, including the presence of any feature of historic, architectural, cultural or similar interest, disregarding, if they think fit, any advertisement being displayed there;
• (b) in the case of public safety —

• (i) the safety of any person who may use any road, railway, tramway, harbour or aerodrome; and
• (ii) whether any display of advertisements is likely to obscure or hinder the ready interpretation of, any traffic sign, railway or tramway signal or aid to navigation by water or air.

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) In determining an application for consent for the display of advertisements, the Department may have regard to any material change in circumstances likely to occur within the period for which the consent is required or granted.
• (3) Unless it appears to the Department to be required in the interests of amenity or public safety, an express consent for the display of advertisements must not contain any limitation or restriction relating to the subject matter, content or design of what is to be displayed.

• 2.10 The Strategic Plan contains two policies of relevance to the determination of the application. General Policy 6 states:

"Within our towns and villages, the display of external advertisements will be permitted on the site or building to which they relate provided they:

• (a) are of a high standard of design and materials and relate well to the building and site on which they are to be displayed;
• (b) are in keeping with and do not detract from the surrounding area; and
• (c) are located so as not to cause a highway safety hazard".

• 2.11 Environment Policy 37 builds on this:

"As a general policy, advertisements within Conservation Areas will be permitted only if:

• i) the proposal preserves or enhances the Conservation Area;
• ii) the signage is in a style appropriate to the character of the area;
• iii) traditional materials and finishes are used and glossy and highly reflective materials are excluded from proposals; and
• iv) internally illuminated box fascia and projecting box signs are excluded from the proposals".

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

• 3.0 Planning history
• 3.1 The site has been the subject of a number of applications for alterations and extensions, the most recent of which being for signage (17/01313/D) which was permitted. In that application the officer notes in his report that “This site and building is somewhat different to the appearance and style of the majority of the Promenaded buildings, being of a 1960s/70's styled building which has a totally different approach and finish to the traditional Victorian seafront properties.”
• 3.2 Smoking shelters were added under 07/02043/B, 07/02045/B and 13/91258/B; new powder coated aluminium windows under 06/00775/B, an accessible ramp under 05/92133/ B and various other modernisations approved and undertaken in the early 2000s.
• 3.3 The most recent application which has yet to be determined, is 23/01434/B which proposes alterations to the first floor bar frontage, to create a balcony facility. The proposed signage relates to the bar which is the subject of that application.
• 3.4 The capital has seen a number of applications for digital sign boards including the following:

• i. 20/01481/D for a Digital Media LED sign at the junction of Pulrose Road and Peel Road permitted.
• ii. 15/00366/D - installation of digital advertising display to ground floor window - permitted.

This site is within the Athol Street/Victoria Street Conservation Area and the proposed sign was 2m by 1.1m and displayed within the window and where the images would change every 15 minutes. In his assessment of the proposal, the planning officer noted that the building in which it would sit had lost most of its original features but retained some and sat opposite one Registered Building and close to others.

• iii. 12/00604/D - erection of illuminated signage. Sea Terminal Building - permitted. This application was determined by the Council of Ministers as the planning authority was at the time, part of the same Department that owned the application site. The inspector who considered the application noted that the signs would be 2.43m by 0.6m and externally illuminated by fluorescent tubes. These signs were proposed on a building which sits within

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

the same Conservation Area as the Palace Hotel. It would appear that the signs which are in situ may not be the size as stated in the application.

The inspector notes:

“The Sea Terminal Building is a landmark gateway for travellers to and from the Island. Its electronic variable signs are eye catching both for their inherent brightness and because the content changes regularly. Those aside, the remaining signage is subordinate to the building, and although intentionally clearly visible it occupies only a tiny proportion of the building’s elevations. The individual signs are also in size and proportions very much in scale with the building’s distinctive modular panel construction. The proposed signs would similarly respect the building’s underlying architecture and these too would relate directly to a service available within the terminal that complements its primary function as a transport terminal. There would be no net increase in signage on the front elevation, where one of the existing signs would be displaced, and a barely perceptible increase in the context of each of the lengthy side elevations. In all the particular circumstances here, external illumination of the face of these modest sized signs would not be out of place or out of character on this busy functional building.

There would be minimal change in the overall appearance of the Sea Terminal and its character would be unchanged. I consider that there would be no material harm to visual amenity and that the character and the overall appearance of the Conservation Area would each be preserved. All told, I consider that the proposal complies with General Policy 6 and Environment Policy 37”.

Below are images of the signs as they currently appear:

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

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

• 4.0 The proposal
• 4.1 Proposed is the removal of the existing Best Western lettering on the side of the projecting bay and its replacement with a single digital signboard. This will measure 3.12m long sitting within the elevation which projects 3.66m from the main frontage of the building. The sign will be 1.76m high and approximately 250mm deep sitting within a metal housing, and will contain series of changing imagery, some of which will contain moving imagery and all of which will relate to facilities and functions within the building to which it will be attached.
• 4.2 The bottom of the sign will sit 2.9m above the pedestrian footway below.

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

• 5.0 Assessment and conclusion
• 5.1 The critical issues in this case are twofold:

• i. Whether the proposal would be harmful to the amenity of the area taking into account the general characteristics of the locality, including the presence of any feature of historic, architectural, cultural or similar interest, disregarding, if appropriate, any advertisement being displayed there; the visual impact on the character and appearance of the building itself, the impact on the special character and appearance of the Conservation Area - having regard to whether the proposal preserves or enhances the character and appearance of the area and finally whether the proposed works would have any impact on the nearby Registered Building and
• ii. Whether the proposal would be harmful to public safety.

Amenity

• 5.2 The works would be contained to a small part of the front facade of the building and within the existing external side walls, resulting in the proposed works being visible only when one approaches the building from the south. This contrasts with the signage on the Sea Terminal which were deliberately sited for maximum visibility. It is fully accepted that the Sea Terminal is a public building with a very different function to the Palace Hotel. However there are also significant comparisons: both buildings are distinct and both are of a similar age and architectural design and finish and both contrast markedly with the buildings in their immediate areas. Some of the advertisements displayed on the Sea Terminal Building do not relate to facilities within that building, as can be seen on the images above.
• 5.3 The application building currently has a front elevation which comprises a number of different sections and which accommodates an array of signs which announce what is available in each different part of the building.
• 5.4 The proposed sign will draw the viewer’s attention to the entrance underneath, which provides access to the bar above and to the restaurant and casino, distinguishing these from the restaurant on the ground floor, accessed from the promenade not within the building, and the Kursaal bingo hall also accessed directly from the promenade.
• 5.5 The existing building is acknowledged in the Conservation Area Appraisal as sitting apart from the rest of the promenades in terms of its style and design and what is proposed will

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

not change that. The building will retain its current character and it is submitted that the signage will not look out of place on this small part of the overall building and not on the building's frontage.

5.6 The works are some distance from the Castle Mona Hotel and contained within one existing side wall projecting section. It is submitted that the proposal will have no adverse impact on this Registered Building or the parade of shops beneath. Similarly, the Falcon Cliff is a prominent building which sits some distance from the proposed signage which is of such a modest size in comparison, we would submit that there will be no adverse impact on the character or setting of that Registered Building either.

Public safety

5.7 The sign will not be visible to vehicles travelling southwards on the promenade and to those travelling northwards the sign will only be visible when relatively close to the sign and as soon as one has passed it, the sign will not be visible. This compares favourably with the signs at the Sea Terminal which are alongside a roundabout and that at the junction of Pulrose Bridge and Peel Road which is alongside a three way traffic light system with two pedestrian crossing points.

General Policy 6 and Environment Policy 37

• 5.8 The proposal is considered to be “of a high standard of design and materials and relates well to the building and site on which it is to be displayed; is in keeping with and does not detract from the surrounding area; and is located so as not to cause a highway safety hazard”. As such, the proposal is considered to accord with General Policy 6.
• 5.9 The proposal is considered to be sympathetic to the modern, lively frontage of the existing building and thus preserves the character and appearance of the Conservation Area at this point. The approved signage at the Sea Terminal demonstrates that digital signage in itself can be appropriate to the character of the area subject to its context and especially attached to a relatively modern building.
• 5.10 Whilst EP37 recommends the use of traditional materials and finishes, in this case, the building to which it would be attached comprises a significant amount of glass and modern frames, contrasting colours of frames and different colours and textures of external render and with significant areas of flat roofing. Traditional signage such as timber or metal signs and painted lettering could be considered to be out of place on such a building and would contrast with the existing signage already displayed on it. The sign would not be glossy or highly reflective and again, the signage in itself is very similar to what has approval and is already in situ on the Sea Terminal Building within the same Conservation Area.
• 5.11 Whilst the sign is technically internally illuminated, it is a relatively slim feature, not a box fascia or projecting box signs and this form of advertising has been accepted elsewhere in this and other Conservation Areas as is demonstrated in section 3 above.
• 5.12 We would submit that the proposal accords with all of the relevant planning policies and would have an acceptable impact on the Conservation Area, the surrounding area more generally and the adjacent Registered Buildings.

Sarah Corlett 21.06.24

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