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5.1 At the present time there is a live planning application to convert houses, apartments and a function room into 41 apartments and an office space on premises in the Town Centre between Arbory Street and Malew Street, and which includes the Callows Yard area between the two. The application reference is 13/00797/B.
5.2 Although the application form states that the residential occupancy will reduce from 108 to 98 as a result of the proposed apartments all being one-bedroom units as opposed to some of the existing units having 2, 3 or 4 bedrooms, the fact that the actual number of available residential units will increase from 16 to 41 is considered to be significant.
5.3 This is likely to result in increased demand for parking within the Town Centre and the immediate surrounding area as there is no car parking provision within the Callows Yard development and the latest development proposals do not incorporate any changes to this situation.
5.4 Whilst it is acknowledged that this application is not directly connected to the application to the Licencing Court for an Off-Licence at 17-19 Malew Street it does provide an indication of the potential for increasing pressures on car parking in Castletown Town Centre as a result of further development and regeneration proposals.
5.5 It is clear from information contained in the Amey Report and reviewed earlier in this statement that there is predicted to be a shortage of publicly available car parking within the Town Centre Zone by 2017. It should also be noted that all of the 195 publicly available off-street parking spaces within the Town Centre Zone have restrictions limiting the length of time vehicles may park which is considered to be an unsatisfactory situation for residential parking.
5.6 If approved and implemented these 41 apartments will have a life well in excess of this timescale and will simply add to the demand for parking which is currently acknowledged by the Minister to be a “long term problem.”.
5.7 The current requirement for parking for residential development is set out in Appendix 7 of the Isle of Man Strategic Plan which was formally adopted in June 2007. This document states that apartments should be provided with 1 space per one-bedroom apartment and 2 spaces for those with 2 or more bedrooms.
5.8 Applying this to the increase in the number of residential units within the Callows Yard development i.e. 25 units, and assuming that the apartments are one-bedroom accommodation, the above standards require a minimum of 25 parking spaces.
5.9 It is not considered feasible for this level of car parking to be provided within the Callows Yard development and even if it were feasible it (the parking provision) would be immediately under pressure from other residents.
5.10 However, if the proposed apartments are capable of being two-person occupancy then the parking requirements increase further. It should also be acknowledged that separate requirements may also be applicable for the proposed office space.
5.11 It is acknowledged that Appendix 7, at Paragraph A.7.1, indicates that within town centres the Department will consider reducing this requirement having regard to the criteria detailed below and that the typical residential standard may be relaxed in accordance with this paragraph.
(a) the location of the housing relative to public transport, employment, and public amenities; (b) the size of the dwelling; (c) any restriction on the nature of the occupancy (such as sheltered housing); and (d) the impact on the character and appearance of the surrounding area.
5.12 However, the key words in this document are “reduce” and “relax”. No mention is made to the potential for parking standards to be completely disregarded.
5.13 It is acknowledged that in his 2006 decision the Minister deemed that parking was not required for the Callows Yard development, however, it is considered that the current development proposals have moved so significantly away from the development proposed at that time that I believe that it is unlikely that this same decision would have been made in the current situation.
6.1 From my review of the various documents in my possession and from information readily available on the internet it is my opinion that the operation of a Tesco Express store at 17-19 Malew Street, Castletown will lead to an increased demand for parking within the immediate town centre area.
6.2 The very nature of the Tesco Express store, which is at Tesco's own admission a "convenience concept" does not lend itself to a lengthy visit to the premises to undertake a full monthly or even weekly shop which would warrant parking in a dedicated parking area, should space be available.
6.3 Instead it focuses on a "top-up" shop or a visit to simply replenish everyday items or those forgotten during a larger shopping trip such as bread and milk etc. This, in my opinion, would encourage people to simply park as close as possible to the store, irrespective of whether there are parking restrictions in force, as the customer is very likely to be inside the store for only a few minutes.
6.4 This, in my opinion, will lead to additional indiscriminate parking in controlled areas i.e. those regulated by parking restrictions such as double yellow lines etc. to the detriment of road safety especially that of pedestrians.
6.5 In addition, problems of enforcing parking restrictions have already been mentioned and it is my view that any local perception that enforcement is unlikely will encourage drivers to disregard these restrictions.
6.6 Turning to the delivery aspect of the proposed Tesco Express store, it is already clear that it cannot be serviced by Tesco's preferred vehicle type (an 18.5 m rigid vehicle) as a trial delivery run was unsuccessful due to the physical constraints of the highway network in the immediate vicinity of the site.
6.7 This is turn will lead to smaller vehicles being used which has the potential to increase the number of daily delivery vehicle visits to the site. It is also envisaged that such deliveries, with the exception of local Manx produce, would also arrive during peak town centre activity hours having had to travel by ferry to the Island and then transfer onto a smaller vehicle either at Tesco's Douglas store or a third party depot, before onward distribution to Castletown.
6.8 It is further considered that the delivery requirements of a Tesco Express store would be more onerous than those of other shops along Malew Street, which are predominantly independent “niche/boutique” type shops or small cafes and restaurants providing facilities for residents, visitors and workers alike.
6.9 The impact of this increase in delivery vehicle activity should not be overlooked in terms of impact upon residential amenity with vehicles manoeuvring in confined areas, audible warning alarms sounding when vehicles are reversing along with the potential for temperature control equipment being operational while deliveries take place.
6.10 I have considered the report of parking in Castletown produced by Amey and have found fundamental issues with it whereby I do not believe that it can be used as a reliable evidence base that parking levels in this area are satisfactory.
6.11 It should also be acknowledged that the Amey report was never commissioned of this specific purpose but that its aim was to provide a platform for the development of public parking policy for the Castletown area.
6.12 In addition it is my view that any overall findings must be set aside in relation to the very specific circumstances of the location of this convenience store and the constraints of the road network.
6.13 Finally, I would conclude that the operation of a Tesco Express at these premises would have a detrimental impact on the operation of the town centre due to its increased demand for parking and increase in delivery traffic generations. These issues would also impact upon the amenity of local residents by virtue of insufficient parking availability, potential for increased indiscriminate parking and general noise and disturbance.
I confirm that insofar as the facts stated in my report are within my own knowledge, I have made clear which they are and I believe them to be true, and that the opinions I have expressed represent my true and complete professional opinion.
Signed K. Smith Dated 2 August 2013
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