Application for Approval in Principle for Conversion to Retail Unit Former Whitestone Car Showroom, Douglas Road, Ballasalla IM9 2LB Retail & Planning Statement
March 2021
Hargest Planning Ltd
Application for Approval in Principle for Conversion to Retail Unit
Former Whitestone Car Showroom, Douglas Road, Ballasalla IM9 2LB
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Table of Contents
1 Introduction 3
2 Retail Appraisal and Sequential Assessment 5
3 Additional Planning Matters 21
4 Appraisal Against Planning Policies 26
5 Summary and Conclusions 32
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Executive Summary
This Statement sets out supporting information for the proposed development of a Winerite neighbourhood store on the vacant site of the former Whitestone car showroom at Douglas Road, Ballasalla. The application is submitted in principle and identifies the provision of a new foodstore together with parking, servicing and areas for landscaping. The proposed store would be operated by Isle of Man Enterprises PLC – a company wholly owned and headquartered in the Isle of Man and, as such, this would maximise the benefit for the local Isle of Man economy.
The Statement has been prepared in a response to request for additional information made by DEFA planning officers. It sets out a retail impact assessment of the proposal, information on the energy impact of the development together with responses on matters raised by objectors including impacts on amenity (noise, lighting and privacy), effect on traffic flows through Ballasalla and car parking. The Statement also reviews the proposed development against relevant policies set out in both the IOM Strategic Plan and IOM Retail Sector Strategy.
• The proposed store would be 645 sq m gross internal floor area and 435 sq m net floor area (sales area).
• The retail impact assessment demonstrates that the proposal will not have a significant impact on the vitality or viability of any town centre or local shopping facilities.
• The assessment also demonstrates that there is a very high level of need for improving the convenience goods retail offer within Ballasalla – at present there is substantial expenditure leakage to other towns (notably Port Erin and Douglas) which is increasing as the population of the village grows rapidly with major new housing development. The proposal will, therefore, significantly reduce leakage and meet both a quantitative and qualitative retail need.
• Reducing very high levels of expenditure leakage will have additional important planning and environmental benefits:
- it will reduce the number and length of car journeys undertaken for shopping purposes;
- it will significantly reduce carbon emissions from transport supporting sustainable development;
- it will improve competition and choice for the benefit of Ballasalla residents;
- it will provide important supporting services for the village which is identified in both the Strategic Plan and Area Plan for the South as an important location for development and expansion;
- it will provide additional local employment opportunities and economic benefits;
- it will utilise a vacant/brownfield site bringing it back into beneficial use supporting sustainable development.
• Subject to the detailed design that would be undertaken as part of an application for Reserved Matters, it has been demonstrated that the proposed development will not have adverse impacts on residential amenity including impacts from noise, lighting and on privacy.
• As an application in principle, the proposal does not provide full design details necessary for a comprehensive energy impact assessment. However, the design will include numerous measures that will result in both improved thermal efficiency reducing energy demand, and the generation of on-site green energy which will significantly reduce net energy demand arising from the proposed development compared to the previous use of the building.
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
• The proposal re-uses an existing building which results in significantly reduced energy demands compared to demolition and rebuild or to new development on a greenfield site in line with emerging IOM Government policy to increase the re-use of vacant and brownfield sites wherever possible..
• Car parking provision has been demonstrated to be in accordance with the standard agreed by DoI Highways officers.
• The proposed store would have minimal impact on traffic flows through the centre of Ballasalla village.
The proposal is identified to be in accord with the aims, objectives, vision and values of the IOM Strategic Plan, Area Plan for the South and IOM Retail Sector Strategy.
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
1 Introduction
1.1 This Statement sets out supporting information for the planning application in principle submitted by Isle of Man Enterprises PLC for the conversion of the former Whitestone Car Showroom to a retail unit (convenience-format foodstore), at Douglas Road, Ballasalla. If approved the proposed retail unit would be operated as a “Winerite” neighbourhood foodstore.
1.2 This statement has been prepared in response to a request for additional information from the Planning & Building Control Directorate, DEFA, sent by email to the agents for the application dated 3rd Feb 2021. This requested the following information to be provided:
• Reasons why an “exception” to established policies should be made to support the proposed development.
• A Retail Impact Assessment.
• Responses to comments submitted by third parties in relation to the application. These comments concern: lighting noise and privacy impacts; impact on the effectiveness of the Ballasalla bypass and traffic flows through the village.
• Provision of an Energy Impact Assessment.
1.3 The email from DEFA also referred to parking standards for the proposed development.
1.4 This statement provides supporting information as follows:
• The remaining parts of Section 1 sets out a brief description of the proposed development.
• Section 2 provides a retail impact assessment of the proposal. This includes an assessment of retail need/deficiencies in Ballasalla.
• Section 3 considers other material planning matters raised including: noise; traffic; parking; visual impacts; and energy.
• Section 4 reviews the proposal in terms of the policies set out in the IOM Strategic Island Plan, Area Plan for the South and the IOM Retail Sector Strategy.
• Section 5 provides a summary and conclusions. Description of Proposed Retail Development
1.5 The proposal comprises a proposal for the re-use of the former Whitestone Car Showroom as a retail unit. The application is submitted in principle with all matters reserved apart from the proposed siting of the building. This allows the identification of the net and gross floorspace of the proposed development but does not set out details such as design, materials, detailed car park layout, means of access or landscaping for the proposal. In determining this application consideration should be given to the principle of the proposed use and not to the reserved matters unless these affect the principle of the proposed development. The submission of the application in principle limits the level of information that can be provided at this stage – for example the application does not contain any detailed specifications for on-site energy generation. This is addressed further in Section 3 below.
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Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
1.6 The proposal is, however, for the conversion of an existing building and its siting. This allows one to identify the floorspace for the proposed retail unit as follows:
• Net (internal) sales floor area – 435 sq m NFA
• Gross (internal) floor area – 630 sq m GFA
• Gross (external) floor area – 645 sq m GFA1
1.7 The proposed foodstore would be operated by Isle of Man Enterprises PLC (IOME) as a “Winerite” format store. This is a store that primarily serves day-to-day convenience goods (i.e. primarily food and drink) but also provides a limited main food offer aimed at serving a relatively local catchment with limited population. This is a relatively new format developed by IOME in 2020 and is aimed at serving local residential areas within urban areas or villages with more dispersed rural catchments. As noted, the 2020 Winerite neighbourhood format, which has slightly over 400 sq m sales area, would also be able to provide some limited main-food shopping thereby reducing the need for residents within Ballasalla to undertake main-food shopping trips, particularly those directed to Tesco at Lake Road in Douglas.
Employment
1.8 The proposed new store would provide employment for approximately 36 staff roughly two thirds of whom would be full time and the remainder part time. This would all be new employment based at the store. This will provide a modest but significant contribution to sustaining and improving employment in the local area. Further local employment will also be generated as a result of construction and maintenance of the store.
1 Measured as 640 sq m GFA by the agents for the application but 644.8 sq m by DEFA – for simplicity the 645 sq m is used in the remainder of this Statement.
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Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
2 Retail Appraisal and Sequential Assessment
Introduction
2.1 This statement provides an assessment of the potential impact of the proposed development in terms of:
• Impact of the proposed development on existing retail centres and locations; and
• Assessment of the extent to which the proposal addresses both quantitative and qualitative retail nned/deficiencies.
Information Sources
2.2 The assessment has used the following base data from the IOM Retail Sector Strategy Evidence Base (“RSS-EB”) (Peter Brett Associates, June 2013) and other sources as follows:
• Net Floorspace (convenience and comparison goods) for all principal retail centres potentially affected by the proposed development (Castletown, Port Erin and Douglas) – RSS-EB Section 2
• Available expenditure per capita to 2013-2022 - RSS-EB Tables 4-2 and 4-5
• Actual store turnover in centres as a share of IOM available expenditure - RSS-EB Tables 3-16, 3-17 and 4-3
• Population for Malew parish – 2011 and 2016 Census (IOM in Numbers 2020)
• Housing consents and completions for Ballasalla - 19/00137/B and Dandara marketing website for “Reayrt Mie”.
• Floorspace of existing convenience goods shops in Ballasalla from Google Earth Pro.
2.3 To provide consistency with the RSS-EB all prices are expressed as 2012-prices. The test year for the assessment is 2024 – this reflects the fact that the current application is in principle which would indicate that the first full year of trading is likely to be 2024. Proposed Store Floorspace and Turnover
2.4 The floorspace of the proposed development was described in Section 1 of this Statement. For the purpose of this retail assessment the following are the key assumptions in relation to floorspace:
• Gross (Internal) floor area = 630 sq m GFA
• Net (sales) floor area = 435 sq m NFA
• Net convenience floor area = 402 sq m NFA (i.e. 92.5% convenience sales)
2.5 IOME have undertaken an assessment of the potential turnover of the proposed store by reference to the turnover of the existing Winerite unit in Douglas, the market area served, the characteristics of the proposed store, and existing competition. The turnover of the proposed new store is set out in Table 2.1.
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Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Table 2.1: Proposed Development Floorspace And Turnover
2012 Prices
GFA NFA Turnover Rate Total Turnover 2020 Proposed New Store Convenience 597 402 £6,145 £2.47m Comparison 48 33 £3,073 £0.10m Total 645 435 £5,915 £2.57m
Notes:
1. Gross internal areas used
2. Average sales density identified at £6500 psm all goods in 2019 prices Conversion to 2012 prices: CPI factor = 0.91 - Table 7 IOM in Numbers 2020
£5,915psm
Catchment Area, Turnover and Market Share
Catchment Area and Population
2.6 The format of the proposed store is aimed at serving a local catchment – essentially the village of Ballasalla and its rural hinterland. For the purpose of this assessment the catchment area has therefore been identified as Malew parish although areas immediately to the east and west of Castletown (Langness and Scarlett) would not be expected to form part of the catchment area for the proposed store. The location of the store and the catchment area is identified in Figure 2.2.
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Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Figure 2.2: Proposed Store Catchment Area
Available Expenditure for Convenience Goods
2.7 Estimates of population and available expenditure (net of special forms of trading) within this catchment area are identified in Table 2.3. Given the minimal population living in those parts of Malew parish not included within the catchment area, the population has been assumed to be 50 less than that identified for the parish as a whole.
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A topographical location map showing a large area outlined in red, centered around Ballasalla and Castletown with a blue star marker.
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Table 2.3: Catchment - Resident Population And Expenditure
2012 Prices
YEAR
POPULATION
Rate Per Head Total £m Rate per Head Total £m<br><br>AVAILABLE EXPENDITURE Convenience Goods Comparison Goods
Notes<br><br>1 MALEW Parish population 2011, 2016 from Isle of Man in Numbers (Census)<br>2 Malew Parish population for 2021 based on 2016 population + 97 units (sold) at "Reayrt Mie", Ballasalla av hhold size of 3 persons<br>3 Malew Parish population for 2024 based on 2016 population + 282 units (sold) at "Reayrt Mie", Ballasalla<br>4 Available Expenditure rates from IOM Retail Sector Strategy Evidence Base: Convenience Comparison<br><br><br>2017 gross SFT £1,881 £2,972 IOMRSS EB Table 4-2 2017 net SFT £1,823 £2,568 IOMRSS EB Table 4-5<br><br>2021 gross SFT £1,926 £3,345 Extrapolated from Table 4-2<br><br>2021 net SFT £1,851 £2,823 Estimated from Table 4-5<br>2022 gross SFT £1,938 £3,445 IOMRSS EB Table 4-2<br><br><br>2022 net SFT £1,859 £2,894 IOMRSS EB Table 4-5 2024 gross SFT £1,961 £3,655 Extrapolated from Table 4-2 2024 net SFT £1,899 £3,070 Estimated from Table 4-5<br>
2.8 The key factor in the identification of population growth is the progress with the Reayrt Mie housing development by Dandara.
2.9 Table 2.3 identifies the current (2021) available expenditure for convenience goods (in 2012 prices) to be £4.46m in 2021 increasing to £5.63m in 2024. Available expenditure for comparison goods rises from £6.80m in 2021 to £9.10m in 2024.
2.10 The assessment assumes that 100% of trade draw to the store would originate from residents living within the catchment area. It is possible that a small proportion would originate from pass-by traffic (including, for example, those travelling between Douglas and Port Erin) but this assumption (i.e. that all trade originates from within the catchment) would result in a marginal over-estimate of retail impact on local shops. This assumption is, therefore, consistent with the adoption of a worse-case approach to assessing impact. Existing Retail Floorspace and Turnover
2.11 Table 2.4 summarises estimates of existing retail floorspace and turnover in the catchment area and in Castletown, Port Erin and Douglas. The only retail units within the catchment area are small shops located within the village of Ballasalla comprising three shops retailing convenience goods, two comparison goods shops and 3 retail services.
2.12 Floorspace in Castletown and Port Erin is from the RSS-EB and turnover is calculated from the market share identified in the RSS-EB (this provides forecast expenditure to 2022 and this has been extrapolated to provide an estimated forecast of actual turnover to 2024).
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Table 2.4: Floorspace And Turnover In 2021 And 2024
2012 Prices
No.
GFA NFA<br><br>Per Sq M Total £m<br><br>Turnover 2020<br><br>Convenience Goods
GFA NFA<br><br>Per Sq M Total £m<br><br>Turnover 2021<br><br>Comparison Goods
GFA NFA<br><br>Per Sq M Total £m<br><br>Turnover 2021<br><br>Comparison Goods
GFA NFA Turnover 2021 Total £m<br><br>All Goods
GFA NFA Turnover 2021 Total £m<br><br>All Goods
GFA NFA Turnover 2021 Total £m<br><br>All Goods
Convenience Comparison Total<br><br>Turnover in 2024<br><br>Total £m
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
Notes:<br><br>1. Floorspace and turnover from IOM Retail Sector Strategy - Evidence Base
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
Expenditure Share
Expenditure Share
Expenditure Share
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
Convenience
Gen Comp
Bulky Goods
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
Castletown Port Erin Douglas CentreSupermarkets<br><br>Other Douglas RemainderSupermarkets
4.3% 7.3% 18.1% 0.9% 35.8%
2.0%<br>3.0% 63.0%<br>
0.1% 0.8%<br><br>0.4%
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
Total IOM Expenditure
Convenience
Gen Comp
BG
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2. Estimated turnover for principal settlements from Tables 3-16, 3-17 and 4-3 of IOMRSS Evidence Base:
2017<br><br>2021<br>2022 2024<br>
£165.55m £172.98m £174.89m £178.77m
£192.86m £221.44m £229.22m £245.62m
£68.74m £78.93m £81.71m £87.56m
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2.13 Table 2.5 shows that the very limited convenience provision within the catchment area (i.e. in Ballasalla) results in an extremely high level expenditure “leakage” to stores outside the catchment. Tables 3-6 and 3-7 of the RSS-EB show that, for the zone in which Malew is located (Zone 4 of the study) this expenditure is directed as follows:
• Main food shopping: 33% to Tesco, Douglas; 50% to Shoprite, Port Erin; 4% other Douglas town centre; and 3% Shoprite, Castletown.
• Top-up shopping: 18% Tesco; 18% Shoprite, Port Erin; 7% Castletown (Co-op and Shoprite) and 9% Douglas town centre.
2.14 Given that Malew is in the northern part of Zone 4 (which also includes all parts of the south excluding Castletown – see RSS-EB Table 1-1) it is reasonable to assume that Malew will have slightly higher proportions of expenditure directed to Douglas (and possibly Castletown) and a slightly lower proportion directed to Port Erin shop.
2.15 The table identifies that that current convenience expenditure leakage is £3.87m per annum i.e. equivalent to 87% of available expenditure. Table 3.5B shows that the quantum of leakage will increase to 2024. Expenditure leakage rates for comparison goods are even higher – equivalent to 96% of available expenditure.
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Trade Diversion and Retail Impact
2.16 Trade diversion estimates have been based on a consideration of each of the following factors:
• Distance between competing stores and proposed development (i.e. extent of over-lapping catchment areas).
• Size of competing store.
• Similarity of retail goods.
2.17 Table 2.6 summarises estimated trade diversion to the proposed foodstore as a percentage of turnover and total trade diversion. Due to the very limited existing retail provision within the catchment area only 5% of convenience turnover of the proposed development would be diverted from local shops. However, close to half (47.5%) is assumed to be diverted from other shops in the South (i.e. Castletown and Port Erin) and a similar proportion would be diverted from shops within Douglas – the majority of this from the Tesco superstore at Lake Road.
2.18 Combining the information from Tables 2.1 and 2.6 allows the calculation of retail impact on shops within the South and Douglas. This is shown in Table 2.7.
2.19 Table 2.7 provides three measures of potential retail impact:
• The first is the percentage reduction in turnover that would result from the proposed development in 2024 compared to the current position in 2021 – this is shown in column E. This takes into account both the direct trade diverted from existing locations to the proposed store together with an allowance for changes in turnover in existing shops/centres that would arise as a result of changes in population and available expenditure. This assumes that existing shopping patterns from residents within the catchment effectively remain the same between 2021 and 2024.
• The second measure (column F) compares the position in 2024 with the proposed development compared to 2024 without the proposed development (i.e. ignores the effects of expenditure growth between 2021 and 2024). This shows a similar pattern of retail impacts to that shown in column E.
• The third measure is a consideration of convenience goods sales densities that would arise with the proposed development (column G). This shows that these residual sales densities will remain healthy for existing shops.
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Development Impact on Retention and Leakage of Expenditure
2.20 Table 2.8 identifies the impact that the proposed development would have on expenditure retention within Ballasalla in 2024. This shows that convenience expenditure retention increases to 55% of total available expenditure (i.e. a net increase of £2.35m) whereas the increase in retention for comparison goods is very limited – increasing to 5% of available expenditure (a net increase of £0.10m).
2.21 The reduction of leakage from Ballasalla will result in a significant net increase in retail employment locally and, through reducing car journeys to shops elsewhere, this will result in significant sustainability benefits. This level of convenience expenditure retention is consistent with the format of the proposed foodstore which, although primarily serving local top-up shopping would also provide a limited amount of main-food shopping provision as well. Sensitivity Tests
2.22 Table 2.9 Presents a series of sensitivity tests to identify how retail impacts on the principal centres in the South would vary if assumptions about proposed development turnover and trade diversion assumptions were altered. The following tests are set out in Table 2.9:
• Test 1: Central Case (as described above)
• Test 2.1: Increase the proposed development turnover by +25% (i.e. to £7394/sq m in 2012 prices)
• Test 2.2: Decrease the proposed development turnover by -25% (i.e. to £4436/sq m in 2012 prices)
• Test 3.1: Increase the trade diversion from Douglas (i.e. Tesco and the town centre) to 60% for convenience goods and 80% for comparison goods with pro rata reductions elsewhere.
• Test 3.2: Decrease the trade diversion from Douglas (i.e. Tesco and the town centre) to 35% for convenience goods and 55% for comparison goods with pro rata increases elsewhere.
2.23 The implications of these sensitivity tests for assessing the significance of retail impact are addressed below.
Table 2.8: Catchment Area - Retention And Leakage - 2024 With Proposed Development
2012 Prices
2024
Convenience Goods
Comparison Goods
Available Expenditure<br><br>Turnover<br><br>Retention<br><br>Leakage (£m) Leakage (%)
£5.63m<br><br>£3.09m<br><br>55%<br><br>£2.54m 45%
£9.10m<br><br>£0.49m<br><br>5%<br><br>£8.61m 95%
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Table 2.9: Sensitivity Tests
Sensitivity Test
2024 with Dvpt v 2024 with Dvpt v 2021 without Dvpt 2024 without Dvpt<br><br>Turnover Change<br><br>Ballasalla
2024 with Dvpt v 2024 with Dvpt v 2021 without Dvpt 2024 without Dvpt<br><br>Castletown Turnover Change
2024 with Dvpt v 2024 with Dvpt v 2021 without Dvpt 2024 without Dvpt<br><br>Port Erin Turnover Change
1. Central Case<br>2. Change Development Turnover<br><br>2.1: Increase Turnover by +25%<br>2.2: Decrease Turnover by -25%<br><br><br>3. Amend Trade Diversion Assumptions<br><br><br>3.1: Increase Trade Diversion from Douglas to 60% convenience and 80% comparison goods<br>3.2: Decrease Trade Diversion from Douglas to 35% convenience and 55% comparison<br>
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Significance of Impact on Vitality and Viability of Centres
2.24 Table 2.7 identified the percentage impact of the proposed development on the retail turnover of existing shops and centres and Table 2.9 demonstrated how these impacts would vary for the principal retail centres in the South with key changes to the retail impact assessment assumptions.
Ballasalla Village Shops
2.25 As would be expected the highest direct percentage impacts of the proposed development (i.e. in 2024 with and without the proposed development) would be on the three existing local shops selling convenience goods within the village. Table 2.7 identifies the impacts to be as follows:
• Convenience goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: +5%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -17%
- Residual sales density after impact: £5252 psm
• Comparison goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: +33%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -1%
2.26 The key issue for assessing the significance of these impacts is the effect that the rapidly growing local population has on available expenditure generated locally and the amount spent in local shops. The Reayrt Mie development, with 282 housing units, represents a substantial increase in Ballasalla’s population. This will have a direct impact on the turnover of existing shops. Table 2.7 shows that, even with the proposed development, the turnover of these existing shops will be slightly higher than is currently the case. The Area Plan for the South also allocates additional major housing land in Ballasalla which, if/when this is brought forward, will further increase population, expenditure and turnover in local shops – this additional housing has not been factored into the assessment.
2.27 Linked to this Table 2.7 column G shows the impact that the combination of the existing housing development and proposed new Winerite would have on the turnover rates of existing shops – this is estimated to increase from an average £5,000 psm at the present time to £5,252 psm – i.e. an increase in overall sales densities even with the proposed new Winerite neighbourhood store.
Conclusion
2.28 The RIA demonstrates that, for the local shops distributed around Ballasalla the proposed development will not affect their vitality or viability – any trade diverted to the proposed new store is more than exceeded by the increased turnover in these shops arising from the rapid increase in population in the village.
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Castletown Town Centre
Town Centre Health Check
2.29 Castletown town centre is a small-mid sized town centre with approximately 54 retail and retail service units and total retail floor area of 2671 sq m GFA. The principal convenience goods shops are the Shoprite and Co-op foodstores. The RIA, using the RSS Evidence Base data, estimates the current turnover of the town centre as £7.44m convenience goods and £4.51m comparison goods.
2.30 In terms of the centre’s vitality and viability the RSS-EB notes the following:
• Castletown is the ancient and historic capital. As a result, it has several tourist attractions including: Castle Rushden, Old House of Keys, The Nautical Museum and the Old Grammar School.
• The town centre is attractive reflecting both the effect of Caste Rushden and the pedestrianised streets. The castle dominates the town centre with the small shopping streets situated adjacent to it.
• Callow’s Yard/The Courtyard is a mixed development scheme. At the time of the RSS-EB (2013) three units were vacant.
• The RSS-EB identified 9 convenience units, 14 comparison goods units and an “adequate” range of retail services.
• In 2013 6 units were vacant (half of these were located in Callow’s Yard) totalling 761 sq m floorspace
– a vacancy rate of 11% by number.
Retail Impact
2.31 Retail impacts from the proposed development are identified to be extremely low:
• Convenience goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: -3%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -6%
- Residual sales density after impact: £4700-£9000 psm
• Comparison goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: +11%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -0%
• All goods:
Impact comparing 2024 turnover with proposed development and current turnover: +2% (sensitivity test range: +2% to +3%)
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Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -3% (sensitivity test range: -3% to -4%)
2.32 From the above the direct impacts in 2024 would be low and cumulative impacts, taking into account changes between 2021 and 2024, would result in turnover being higher in the town centre despite limited trade diversion to the proposed store. Taking all of the above factors into account the proposed development at Ballasalla would not affect the vitality or viability of Castletown town centre.
Port Erin Town Centre
Town Centre Health Check
2.33 Port Erin is identified as a Service Centre in the IOM Strategic Plan. Although it has a similar total number of retail/retail service units as Castletown the total retail floorspace is significantly larger. In total there are 58 retail and retail service units and total retail floor area of 5290 sq m GFA (excluding retail services). The principal convenience goods shops are the Shoprite and Co-op foodstores. The RIA estimates the current turnover of the town centre as £12.63m convenience goods and £7.27m comparison goods.
2.34 In terms of the centre’s vitality and viability the RSS-EB notes the following:
• Port Erin is the principal convenience retail centre in the South.
• The RSS-EB identified 10 convenience units, a broad range of comparison retailers (17 units are identified in the RIA) and an “wide” range of retail services.
• In 2013 3 units were vacant – a vacancy rate of 5% by number.
• The town environment is described as “fair” but some shop units are in a poor condition whereas other buildings, especially along the waterfront have been or were being refurbished.
Retail Impact
2.35 Retail impacts from the proposed development are identified to be extremely low:
• Convenience goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: -2%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -6%
- Residual sales density after impact: £3800-£7300 psm
• Comparison goods shops:
- Impact comparing 2024 turnover with proposed development and current turnover: +11%
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -0%
• All goods:
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- Impact comparing 2024 turnover with proposed development and current turnover: +2% (sensitivity test range: +1% to +3%)
- Impact comparing 2024 turnover with proposed development with turnover in 2024 without proposed development: -4% (sensitivity test range: -1% to -5%)
2.36 From the above the direct impacts in 2024 would be low and cumulative impacts, taking into account changes between 2021 and 2024, would result in turnover being higher in the town centre despite limited trade diversion to the proposed store. Taking all of the above factors into account the proposed development at Ballasalla would not affect the vitality or viability of Port Erin town centre.
Douglas
2.37 Table 2.7 also identified impacts on shops in Douglas town centre and also the Tesco superstore at Lake Road. As a result of the large size of the centre and limited trade diversion, impacts arising from the proposed development would be negligible. Direct impacts in 2024 (with the proposed development compared to the situation without would be less than 0.2%) and turnover in the centre would be greater in 2024 with the proposed development compared to the current situation.
2.38 Impacts on major foodstores located outside the town centre (notably Tesco at Lake Road) would also be extremely low with a direct impact on 2024 of -1% but turnover would be higher than is currently the situation in 2021.
2.39 The proposed development would have no effect on the vitality or viability of stores within Douglas town centre or elsewhere in the town.
Conclusions
2.40 The conclusion from the retail impact assessment is that the proposed development will not affect the vitality or viability of any centre potentially affected by the proposal nor would the development affect the viability of individual stores located within Ballasalla. Retail Deficiencies
Quantitative Deficiencies in Catchment Area: Impact on Expenditure Leakage
2.41 The quantitative retail analysis set out above shows that, for the catchment area of the proposed store as a whole, there is a substantial net leakage of convenience expenditure from the Ballasalla/Malew area. This confirms that there is a substantial quantitative retail deficiency for convenience goods retailing. Table 2.5 shows that, at present, 87% of expenditure on convenience goods generated from residents within the catchment area “leaks” to locations outside the catchment – equivalent to almost £3.9m per annum. The proposed new Winerite will have a significant effect in reducing this leakage and help address this quantitative need/deficiency.
2.42 Increased retention of expenditure within the local area will have significant employment and environmental benefits:
• Retention of spend will increase retail employment opportunities for local residents in Ballasalla.
• It will reduce travel to other locations resulting in significant reductions in journeys made and carbon emissions associated with these journeys (particularly for those made by private car) supporting overall environmental sustainability in line with the broad environmental objections of the Strategic Plan.
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Quantitative Deficiencies: Meeting the Needs of a Growing Population
2.43 Ballasalla is experiencing rapid population growth as a result of the development of planning consent 19/00137/B (Dandara – Reayrt Mie) which provides 282 predominantly family housing. Assuming an average household size of 3 persons (in the first phase of the development there were an average of 3.1 bedrooms per dwelling) this equates to +846 population which generates £1.61m additional available expenditure for convenience goods within Ballasalla. This development alone accounts for 65% of the convenience turnover of the proposed development. There are also direct footpath links between the the application site and the Reayrt Mie housing development and the Abbotswood estate.
2.44 This assessment does not take into account any additional housing development – for example the Crossag Farm site is a 13.0ha site allocated for housing as Site 2 in the Area Plan for the South. Development of this site will result in available expenditure generated by additional population in new housing sites exceeding the convenience turnover of the proposed foodstore.
Qualitative Deficiencies in the Catchment Area
2.45 There is minimal retail provision within the catchment area. Within Ballasalla only three small convenience shops have been identified and there are no modern foodstores present in the area supporting any main food shopping. The nearest significant foodstores are in Port Erin and Castletown. These factors indicate a qualitative retail deficiency within the catchment that would be addressed, in part at least, by the proposed development. Retail Assessment - Summary and Conclusions
2.46 An assessment of the retail impact of the proposed development has been undertaken. This has considered the market area that would be served by the proposal, existing retail floorspace and turnover, the proposed development turnover, trade diversion and has used different measures of retail impact. The assessment has also considered the vitality and viability of retail centres/shops affected by the proposed development. The principal findings of the assessment are:
• The proposed development would not affect the vitality or viability of any retail centre within the Isle of Man nor adversely affect the viability of local retail facilities located in Ballasalla.
• It has been demonstrated that there is a significant retail need for the proposed development. This reflects the high level of existing retail leakage, especially for convenience goods, from Ballasalla. In addition, the village has a rapidly growing population and the proposal will meet the needs of new residents.
• Reducing expenditure leakage will result in important environmental and economic benefits for the local area and reduce carbon emissions thereby supporting sustainable development.
• The proposal will provide a new modern retail facility within a local area that has no modern retail units; and it would support walk-in trade in an area particularly from the nearby residential development.
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3 Additional Planning Matters
Introduction
3.1 DEFA has requested that responses are made to points raised by consultees and objectors to the proposed development together with information on the energy impact of, and parking provision for, the development proposals. These matters are addressed in this section and include the following:
• Impacts of the development in terms of noise, light and privacy (raised by local residents).
• Effect of the proposal on traffic levels through the village (raised by Malew Commissioners and local residents).
• Lack of need for additional convenience retail/role of provision within Service Villages (raised by local residents).
• Impact on viability of existing village shops (Mannin Retail)
• Possible impact on privacy arising from the proposed car park on adjacent property.
• Effects of noise on local amenity.
• Effects of lighting on local amenity.
Privacy
3.3 There are a number of factors in the proposed siting that will ensure that the development will not affect the privacy of the residents of Monaltrie:
• None of the car spaces face Monaltrie, they are perpendicular to the shared boundary with Monaltrie
• The nearest car space is 14m from the garden boundary, and 27m from the house.
• Although a reserved matter the applications have indicated the provision of a new 1800mm high fence on the proposed layout between the car park and Monaltrie and this is in addition to the visual screening already provided by the trees and shrubs located between the car park and the dwelling.
3.4 As a result of the combination of the parking alignment, the distances from the nearest parking space, the screening provided by the fence and the additional screening provided by the trees and shrubs, this will ensure there will be no loss of privacy for residents in this dwelling.
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Noise
3.5 Gardens of dwellings to the east of the application site (Nane Darragh and Monaltrie) are located 14-18m away from the proposed car park area and the dwellings are further from the car park – this is a significant distance and is extremely unlikely to result in any disturbance.
3.6 Reflecting the limited size of the store total vehicles movements will be relatively small. Based on the characteristics of the existing, larger, Winerite store in Douglas, it is estimated that the average number of customers arriving by car, would be in the region of 25 per hour, which would result in limited noise levels. The service delivery area is located on the west side of the proposed foodstore. Even at peak hours noise from traffic movements from customers would, therefore, be very limited.
3.7 Deliveries will be by a small rigid goods vehicle with tail lift and as confirmed in the Planning Statement that accompanied the application, deliveries would be restricted to between 10am and 8pm – the applicants confirm that they would accept a condition that restricts deliveries to these times. Measures will be implemented in accordance with the principles established in the UK Dept of Transport “Quiet Deliveries Good Practice Guidance – Key Principles and Processes for Retailers” (2014).
3.8 The acceptability of well managed retail foodstores located adjacent to housing is well established in the Isle of Man – for example each of the Shoprite foodstores in Castletown, Port Erin and Peel are located close to housing and do not have unacceptable impacts on residential amenity including noise.
Lighting
3.9 The design of the proposed lighting is not included in the current application but will require to be approved at the reserved matters stage but it will be very carefully considered to ensure that this will not adversely affect the local area and neighbours. Lighting columns will meet modern energy standards using low demand LED downlighters with minimal spillage and will be set to timers restricting illumination to the hours of store opening/deliveries only. The applicants are content that conditions are attached to the planning approval to give effect to this commitment.
3.10 Concern has been raised by the residents of Nane Darragh but the garden of this dwelling is over 12m from the nearest part of the car park and 34m from the nearest part of the house so it will be at least this distance from the nearest lighting column. Traffic and Ballasalla Bypass
3.11 It is considered that the proposed foodstore would have a minimal impact on traffic flows through the centre of Ballasalla and it would not undermine the effect of the bypass. There are a number of factors that would indicate that this would be the case:
• The principal role of the bypass is to provide direct access between Douglas (and the rest of the Island) with the airport, Balthane IE and Castletown. It will have no effect on traffic flows between Douglas and Port Erin and the remaining parts of the South.
• In order to use the store a traveller from the Castletown/airport area has two options – either to travel through the village or to use the bypass and travel between the bypass junction in the north and the proposed store (a distance of about 500m). Given the need to cross the railway (which could, at certain times, result in significant delays) and to travel at reduced speeds through the village many drivers would consider that, if they wish to use the store, using the bypass and then travelling along Douglas Road, would be the more attractive option. This will mitigate journeys through the centre of the village.
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• The numbers who would wish to use the proposed store en route between Castletown/airport and Douglas will be relatively few. Although it is large in comparison to other stores in Ballasalla, the proposed store is, nonetheless, relatively small. It would be only about one third the size of the Port Erin Shoprite and 15% the size of Tesco at Lake Road. The store would be only slightly larger than the Shoprite store in Castletown. The key point is that there would only be a limited benefit for someone travelling between Castletown or the airport/Balthane area to divert away from their journey route in order to use the proposed store given the existing shops located either in Castletown or Douglas.
• The bypass will have no effect on reducing traffic movements between the remainder of the South and Douglas – even with the bypass the shortest and quickest route will remain travelling through the village centre and using the A7. Travellers on this route will be travelling directly past the proposed store and so, even though the store is smaller than in Port Erin or Douglas, it could prove attractive to a few shoppers because there would be no diversion required to access the store. For these shoppers the store will have no impact on traffic flows in the village because they will be making the journey already.
• Finally, apart from the limited pass-by trade noted above, the proposed store would be too small to draw trade into Ballasalla from areas beyond the immediately local area. This is because the store would not be large enough to attract trade from either Castletown or any area relatively close to Port Erin. It will not, therefore, result in additional traffic coming into the village to access the store.
3.12 All of these factors indicate that the proposed foodstore would not have a discernible impact on traffic flows through the centre of Ballasalla. Retail Provision and Impacts
3.13 Apart from policy (which is considered in Section 4 of this Statement) objectors raise two matters relevant to retail impact: need for the proposed floorspace; and impact on the viability of existing shops in Ballasalla.
Need
3.14 Section 2 has demonstrated that there is, in fact, a pressing need for additional convenience floorspace to meet the day-to-day needs of both the existing population of the village and to cater for the needs of its growing population. The level of leakage, equivalent to 87% of the available expenditure generated within the village, is extremely high and should be regarded as a matter of particular concern. The only convenience goods shops within the village serve local top-up shopping requirements and none are able to meet any main food shopping needs. As a result, almost all food shopping trips are directed to stores in Port Erin, Douglas and, to a more limited extent, Castletown. This results in a high number of car journeys and excessive carbon emissions which is wholly incompatible with the sustainable vision for the Island set out in the Strategic Plan. The suggestion that there are already sufficient food shops within the village is without merit.
Impact
3.15 The RIA set out in Section 2 demonstrates that the proposal will result in the diversion of trade from existing shops. However, this occurs in the context of a very rapidly growing retail market and, even with trade diverted to the proposed new foodstore, existing shops will experience a net growth in turnover and their viability will be unaffected by the proposed development. This is shown in Tables 2.7 and 2.8 above.
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Energy Impact Assessment
3.16 The IOM Strategic Plan glossary defines an Energy Impact Assessment as “an assessment, prepared by the developer/applicant, of the impacts of the development in terms of energy consumption, and proposals for reducing that consumption and improving the energy efficiency of the development.” The current application is submitted in principle with only the siting of the building identified as part of the application. This application has been registered as a valid application.
3.17 As an application in principle all detailed matters apart from siting (including materials etc) are reserved matters and it is not possible, therefore, to undertake a detailed assessment of the impact that the proposed development will have in terms of energy consumption. Nonetheless there are a number of key principles that would be adopted in the detailed design of the proposed development that will ensure energy consumption is minimised and, importantly, will provide a significant improvement in terms of reducing energy consumption compared to the previous use of the building as a car showroom. These measures include:
• Reducing heat loss through building envelope and filtration (e.g. high levels of thermal insulation and making the building air-tight)
• Incorporation of energy efficient heating and cooling systems for the building (e.g. using thermostatic controls and heat recovery on exhausted air).
• Smart zoning and time-programming on all systems to ensure that heating/lighting systems only operate when required.
• Use of heat recovery from systems (including for example heat recovery from freezer cabinets)
• Energy efficient freezer and refrigeration cabinets.
• Energy efficient LED light fittings in-store and car park lighting.
• Solar photo-voltaic panels on the building roof to generate electricity for lighting and small power.
3.18 The current proposal is aimed at re-using the existing building rather than constructing a new/replacement building on site. This alone represents a major efficiency in terms of minimising energy consumption. Furthermore, the energy/thermal efficiency of the building will also be significantly improved as a result of the above measures and will achieve notable reductions in energy consumption associated with the operation of the proposed use compared to its former use as a car showroom (taking into account the different opening periods and activity undertaken within the building).
3.19 The applicant confirms that a full Energy Impact Assessment which will be able to quantify the scale of energy improvements would be undertaken at the reserve matters stage and would support the inclusion of a condition attached to the grant of planning permission in principle which requires a full energy impact assessment to be undertaken. Parking Provision
3.20 In the absence of relevant parking standards for out-of-centre retail floorspace in Appendix 7 of the IOM Strategic Plan the agents consulted DoI Highway Services in advance of the submission of the planning application. This correspondence is provided at Appendix 1. Particular reference should be made to the email of Niall McGarrigle 8/10/20 para 4 which refers to proposed standard of 1 space per 15 sq m nett and the acceptance of this by Ms Sheila Henley of DOI Highways para iv line 2. DOI Highways therefore
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have confirmed and accepted that the provision of one parking space per 15 sq m net retail floor area is reasonable. In this regard net retail refers to the area used for the sale or display of retail goods and, as set out in Table 2.1, the net floor area of the proposal is 435 sq m which equates to a requirement for 29 parking spaces. The proposed layout confirms the provision of 29 parking spaces.
3.21 This confirms that the proposal is providing the appropriate level of parking approved by DoI Highways officers.
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4 Appraisal Against Planning Policies
4.1 This Section assesses the proposed development against policies contained within the IOM Strategic Plan and the IOM retail Sector Strategy as requested by DEFA planning officers. IOM Strategic Plan
Spatial Strategy
4.2 Ballasalla is identified as a Service Village in the Strategic Plan however the Spatial Strategy identifies that the village has an important role in the South - para 5.8 states:
The aim of the CENTRES, LINKS and GATEWAY approach is to give a strategic focus to future development and achieve balanced growth on the Island by developing:
• …a network of local centres in the south with new development focused on the regeneration of existing centres but recognising the growth potential around Ballasalla and the Airport Gateway.
4.3 Although para 5.11 refers to the role of housing, employment and leisure opportunities in Castletown, Port Erin and Port St Mary, the Area Plan for the South (APS) has directed the majority of new housing development not to these three Service Centres but, instead, to Ballasalla. In total the APS identifies 18 predominantly residential and mixed use sites with a total area for housing (including mixed use) of 49.7ha, however, the two sites in Ballasalla total 32 ha i.e. 64% of the total land allocated for new housing development in the South2. Any consideration of the spatial policy set out in the Strategic Plan needs to be considered in the context of the importance of Ballasalla as the principal location for residential development in the South which accounts for a large majority of all new housing allocations in the South.
Spatial Policy 2
4.4 Spatial Policy 2 states that:
4.5 In considering the relevance of this policy to the current application it is essential that the policy is read in its own terms and in the context of the Area Plan for the South:
• The policy is, primarily, a basis for the preparation of Area Plans in that, in giving effect to the direction of new development, it is for the Area Plans to identify the boundaries for development.
2 Housing and mixed use sites are sites 1,2,3,7,8,9,12,13,14,1,6,17,18,19,20,21,22,23,& 25 – total area 49.69ha. Ballasalla sites are sites 2 & 3 – total area of 32.0 ha.
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• The plan does not say anything about the relevance of the policy for proposals in locations other than the Service Centres. Although the policy aim is, in the first instance, to the Service Centres, it does not indicate that proposals outwith the Service Centres will be considered contrary to the spatial strategy.
4.6 These factors are critical. Although the IOM Planning System is separate from that found in the UK it does, nonetheless, draw heavily from the principles established in the UK planning systems. In this regard the Supreme Court decision Tesco Stores v Dundee City Council 2012 is important in that this confirms the principle that the interpretation of policy must be based on the plain English reading of that policy – it is not up to the decision-maker to impose his/her own interpretation on that policy if it is contrary to the plain meaning set out in the text.
4.7 In this context it can be seen that both the Spatial Strategy in the Strategic Plan identifies a particularly important role for Ballasalla in support new development in the South and the APS gives effect to this by allocating the large majority of all new residential to development in the South to Ballasalla and not to the Services Centres of Port Erin, Castletown and Port St Mary. It is clear therefore, that the provision of new retail services, on a site that has an established commercial use, is consistent with and supports the Spatial Strategy. It follows that the proposal does not conflict with, but supports, Spatial Policy 2.
Benefits of the Proposed Development
4.8 Regardless of the above it is also clear that the proposed development has substantial benefits that also need to be considered:
• The proposal helps to address a substantial need for additional convenience floorspace in Ballasalla to support both the existing population of the village and the ongoing new housing development in the village.
• The proposal will reduce the need to travel for local residents to undertake shopping. At present most residents travel to Port Erin and Douglas for most of their food shopping requirements. This proposal reduces the need to travel resulting in reduced travel time, journey distances and substantially reduces carbon emissions associated with these journeys. This is a major sustainable development benefit.
• The proposal re-uses an existing brownfield/vacant building/site. This results in environmental improvements in the local area and minimises demand for new greenfield development. This also provides an important sustainable benefit.
• The proposal will provide significant new local employment opportunities and economic benefit for the village. This is in accord with Business Policy 1.
• The proposal significantly improves competition and choice for local residents which is identified as an important “value” in the IOM retail Sector Strategy.
Business Policy 5
4.9 This policy only applies to land zoned for industrial use and does not, therefore, apply to the application site.
Business Policy 9
4.10 This policy states:
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4.11 The proposed development is designed to serve the village of Ballasalla and its rural hinterland (effectively Malew parish). Although the village has a small number of shops these are not concentrated in a single location and it would not be reasonable to consider that there is an established existing retail area within the village. It is, therefore, not possible to comply with this policy to provide retail that will meet the needs of the village. In this sense it is accepted that the proposal does not comply with the strict wording of this policy. However, as noted above, the result of this is that Ballasalla does not have adequate retail provision to meet its own needs resulting in residents having to travel to Port Erin and Douglas to meet food shopping requirements. This continuation of this situation, quite apart from the fact that this conflicts with the adverse environmental and sustainable aims of the Strategic Plan, is in conflict with the Spatial Strategy and wit the Area Plan for the South which identifies the importance of the growth of Ballasalla.
4.12 In this context there is a clear need for significant new convenience retail floorspace within Ballasalla. In an ideal situation this would be located in the heart of the village as close as possible to shops located at the junctions of Douglas Road/Main Road or Main Road/Bridge Road (identified as a mixed use area in the Area Plan), however, there are no potential sites or premises in these areas that would be able to accommodate a significant new retail unit. The application site is the next best option since it re-uses an existing commercial unit, it is located within the urban area of the village, and is a site within easy walking distance of much of the village and new housing areas thereby encouraging active travel.
4.13 In terms of the requirement for a Retail Impact Assessment this has been set out in Section 2 of this Statement. This confirms that the proposal will not threaten the vitality or viability of any existing retail locations.
Business Policy 10
4.14 This Policy states:
4.15 The Area Plan for the South does not identify a village centre in Ballasalla although it does identify a mixeduse area extending along Main Road between Bridge Road and Douglas Road. As noted above there are no potential locations in this area capable of accommodating a significant new retail proposal capable of addressing the convenience goods shopping needs of the village and its rapidly growing population.
4.16 In terms of the wording of the policy it is accepted that the policy does not allow for any possible exceptions to the policy apart from those identified in Business Policy 5. However, the same comments apply as identified for Business Policy 9 that:
• there are no suitable sites/premises within the mixed-use area of the village;
• the proposed site is within easy walking distance of most of the existing village and new housing areas;
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• the proposal will substantially reduce the excessive levels of expenditure leakage currently leaving the village for stores in Douglas and Port Erin;
• the proposal will reduce the need to travel resulting in very important reduction in carbon emissions supporting sustainable development; and
• the proposal re-uses a vacant/brownfield site also support sustainable development aims.
• The proposal significantly improves competition and choice for local residents which is identified as an important “value” in the IOM retail Sector Strategy.
Energy Policy 5
4.17 Energy Policy 5 states that “Pending the preparation and adoption of that PPS the Department will require proposals for more than 5 dwellings or 100 square metres of other development to be accompanied by an Energy Impact Assessment”. The supporting text (para 12.2.11) identifies the purpose of this Energy Impact Assessment is to demonstrate what measures have been taken in the design of the development to reduce energy consumption and increase energy efficiency.
4.18 As described in Section 3 above the proposed development is submitted in principle at this stage and detailed design of energy efficiency measures are not available as part of this application. However, a range of measures have been identified which will be incorporated into the design including both increasing thermal insulation resulting in reduced heat loss (thereby minimising energy consumption) and measures to generate energy on site through the use of solar panels which will further minimise energy demand. Equally important is that fact that these measures will be introduced on an existing building which will result in a significant reduction in energy consumption and carbon emissions compared to the previous use. Furthermore, re-using an existing building will minimise energy consumption compared to new build on the site, which will further support the aims of Energy Policy 5.
Strategic Plan – Conclusions
4.19 Taking into account both the specific wording of policies, the importance of development in Ballasalla supporting development in the South, the lack of alternative options within the village, the pressing need to address the substantial leakage of expenditure from the village, and lack of adverse retail impacts arising from the proposed development, it is concluded that the proposed development is strongly supportive of the aims and objectives of the IOM Strategic Plan. IOM Retail Sector Strategy
4.20 The request for additional information received from DEFA identified the need for a supporting statement that referred to both planning policies and also the DED Retail Sector Strategy (2013). Much of the Retail Sector Strategy (RSS) is concerned with a review of the condition of retailing within the Isle of Man and a wide range of practical actions which have limited relevance to the development of a proposed new unit (for example recommendations in relation to marketing and staff training etc). There are, however, aspects of the overall RSS Vision and Values are relevant to the proposed re-use of the Whitestone Garage as a foodstore.
RSS Vision Statement
4.21 The RSS Vision Statement: states: “To promote competitive and accessible retail and leisure environments in our town centres, which offer choice and convenience for consumer’s, improve the economy and enhance resident’s quality of life”.
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4.22 The Vision Statement supports the focus of retail to be within the Island’s town centres. However, one of the reasons given for this is that town centres should be the locations for offering choice and convenience for consumers, improve the economy and enhance residents’ quality of life. In the case of Ballasalla, despite being a significant size and experiencing very rapid population growth, the village does not have a centre. Furthermore, as demonstrated in previous sections, the village has a minimal retail offer with the result that existing provision fails to provide choice and convenience and, as a result, the quality of life for local residents (insofar as affected by easy access to shopping) is undermined. Residents are forced to travel to Port Erin and Douglas to undertake their principal food shopping trips (or have home delivery) because there is no choice available locally.
4.23 The current proposal provides some redressing of this imbalance and, through providing local competition and choice, the proposed development will provide a significant enhancement of Ballasalla residents’ quality of life. In this way the proposed development supports the overall Vision of the RSS.
Competition and Choice
4.24 The RSS identifies four interconnected “values”, two of which are directly relevant to the proposed development which are: supporting variety and competition; and developing the indigenous retail sector.
4.25 In terms of competition and choice the RSS states “Identifying and enabling opportunities for existing retailers and those not yet represented to develop formats which can adapt to changing retailer requirements in Douglas and other central areas is critical”.
4.26 The Winerite neighbourhood format is specifically formulated to meet the needs of a community of the size of Ballasalla. The format is able to meet top-up shopping needs of residents and also to provide a limited offer for main-food shopping needs, it is, therefore, able to provide more than a local convenience-format offering but is appropriate in size for the community in which it is located. The Winerite format is relatively novel in the Isle of Man with only one other store of this type located in Douglas.
4.27 At a more general level Ballasalla has minimal choice for local residents. The village has three small convenience-format stores that serve limited top-up functions and no main-food shopping requirements. As a result, there is an extremely high level of expenditure leakage. Section 2 has demonstrated that the proposed development will, to a significant degree, address this issue and will provide an important extension to the choice and competition for food shopping to Ballasalla residents.
Developing the Indigenous Retail Sector
4.28 The RSS emphasises the economic benefits of supporting indigenous Isle of Man retailers. The benefits identified in the RSS include that:
• local retailers can potentially tailor their retail offer more closely to the requirements of local residents (para 3.27);
• locally owned businesses retain a greater percentage of profit on-Island, generating more benefit through its investment and purchasing effects locally (para 3.32);
• it supports a diverse retail offer distinct from that seen in many UK centres (para 3.29); and
• as a locally owned business, Isle of Man Enterprises PLC offers a significant locally produced range
4.29 Strictly speaking the operator for a foodstore is not a planning consideration since planning permission is normally granted for a proposed use and not an operator. However, in this instance, it is a fact that the
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operator would be IOME which is an indigenous Isle of Man retailer and approving the development of the current proposal will support this “value” identified in the RSS.
Accessibility
4.30 The RSS identifies accessibility for the shopping public as a critical issue (para 3.43) and it recognises that the private car is the transport mode of choice for shopping trips (para 3.44). The RSS sets out advice for supporting accessibility in town centres but it is important also to recognise the importance of improving access to shopping which will reduce the need to travel significant distances for basic shopping requirements. The proposed development will significantly enhance accessibility for food shopping in Ballasalla.
RSS Conclusions
4.31 The current proposal for a foodstore at the former Whitestone Car Showroom, even though it is not located within a defined town centre, is supported by and supports the Vision and Values of the RSS. This reflects the fact that the store would significantly improve accessibility to, and competition and choice for, Ballasalla residents for basic food shopping requirements. Furthermore, the applicant is a local Isle of Man retailer and the RSS emphasises that this results in significant benefits for the local economy and character of shopping on the Island and, as a result, strongly supports the promotion of maximising local retail ownership.
4.32 In conclusion the proposed development supports, and is supported by, the IOM Retail Sector Strategy.
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Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
5 Summary and Conclusions
5.1 This Statement sets out supporting information for the proposed development of a Winerite neighbourhood foodstore on the vacant site of the former Whitestone car showroom at Douglas Road, Ballasalla. The application is submitted in principle and identifies the provision of a new foodstore together with parking, servicing and areas for landscaping. The proposed store would be operated by Isle of Man Enterprises PLC – a company wholly owned and headquartered in the Isle of Man and, as such, this would maximise the benefit for the local Isle of Man economy.
5.2 The Statement has been prepared in a response to request for additional information made by DEFA planning officers. It sets out a retail impact assessment of the proposal, information on the energy impact of the development together with responses on matters raised by objectors including impacts on amenity (noise, lighting and privacy), effect on traffic flows through Ballasalla and car parking. The Statement also reviews the proposed development against relevant policies set out in both the IOM Strategic Plan and IOM Retail Sector Strategy.
• The proposed store would be 645 sq m gross internal floor area and 435 sq m net floor area (sales area).
• The retail impact assessment demonstrates that the proposal will not have a significant impact on the vitality or viability of any town centre or local shopping facilities.
• The assessment also demonstrates that there is a very high level of need for improving the convenience goods retail offer within Ballasalla – at present there is substantial expenditure leakage to other towns (notably Port Erin and Douglas) which will increase as the population of the town grows rapidly with major new housing development. The proposal will, therefore, significantly reduce leakage and meet both a quantitative and qualitative retail need.
• Reducing very high levels of expenditure leakage will have additional important planning and environmental benefits:
- it will reduce the number and length of car journeys undertaken for shopping purposes;
- it will significantly reduce carbon emissions supporting sustainable development;
- it will improve competition and choice for the benefit of Ballasalla residents;
- it will provide important supporting services for the village which is identified in both the Strategic Plan and Area Plan for the South as an important location for development and expansion;
- it will provide additional local employment opportunities and economic benefits;
- it will utilise a vacant/brownfield site bringing it back into beneficial use supporting sustainable development.
• Subject to the detailed design that would be undertaken as part of an application for Reserved Matters, it has been demonstrated that the proposed development will not have adverse impacts on residential amenity including impacts from noise, lighting and on privacy.
• As an application in principle, the proposal does not provide full design details necessary for a comprehensive energy impact assessment. However, the design will include numerous measures that will result in both improved thermal efficiency thereby reducing energy demand, and the generation
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
of on-site green energy which will significantly reduce net energy demand arising from the proposed development compared to the previous use of the building.
• The proposal re-uses an existing building which results in significantly reduced energy demands compared to demolition and rebuild or to new development on a greenfield site.
• Car parking provision has been demonstrated to be in accordance with the standard agreed by DoI Highways.
• The proposed store would have minimal impact on traffic flows through the centre of Ballasalla village.
• The proposal is identified to be in accord with the aims, objectives, vision and values of the IOM Strategic Plan, Area Plan for the South and IOM Retail Sector Strategy.
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
Appendix 1: Parking Standards Correspondence
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
March 2021 Hargest Planning Ltd
Proposed Conversion to Retail Unit 20/01446/A Former Whitestone Car Showroom, Douglas Road, Ballasalla Retail & Planning Statement
March 2021 Hargest Planning Ltd
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Source & Provenance
Official reference
25/90506/B
Source authority
Isle of Man Government Planning & Building Control
