Planning Statement

Planning Statement In Respect Of The Proposed Change Of Use Of Office (Class 2.1) To Private Medical Facility (Classes 3.2 And 4.1), Howard Pearson House, Summerhill Business Park, Victoria Road, Douglas Im2 4Rp

• 1.0 INTRODUCTION
• 1.1 The premises are an office building - Howard Pearson House - and associated car park situated on the south eastern side of Victoria Road in Douglas, within the Summerhill Business Park which also accommodates three other office buildings - Milliennium House to the south east which is presently vacant; Snaefell House and Centre House to the north west and the premises of IQ-EQ which sits to the north east alongside Victoria Road.
• 1.2 To the immediate north east of the business park are residential properties, some of which are Registered and the group bounded by Little Switzerland is a designated Conservation Area. To the south west is a vacant site which has planning approval for a large office and associated residential accommodation campus which has commenced but is presently not the subject of any activity. On the other side of Victoria Road is the Tesco supermarket with Eastfield - a Department of Health facility - to the north west.
• 1.3 The site is accessed both from Victoria Road and also Switzerland Road which meets Victoria Road at its north western end, continues past the business park then becomes a pedestrian route only until it meets the vehicular highway near to the former church, now a dance studio, before continuing to Douglas Promenade.
• 1.4 The building on the site has two storeys of accommodation and around 88 car parking spaces and bicycle store. There is landscaping around the site and mature trees to the north west and south west.
• 1.5 The building is currently unoccupied and has been marketed for sale. The building has a footprint of approximately 1,800 sq m. The floors are largely open plan with toilet and plant rooms and a small central enclosed courtyard with pedestrian access from within the building at ground floor level. There is currently 1,060 sq m nett on the ground floor and 1,188 nett sq m on the first floor, a total of 2,248 sq m nett of office floorspace.
• 1.6 The building is a modern structure with large areas of glazing on the first floor, shallow pitched, hipped, slated roof and a glazed full height entrance facility on the south eastern elevation.

South eastern elevation

Car parking area to the east of the building

View along the south western elevation towards Centre House to the north west

• 2.0 PLANNING STATUS
• 2.1 The site is understood to have been approved for use as an office/business technology facility following applications in the late 1990s for such development. The most recent application on the site, in 2006 was by RBS and noted in the planning officer’s report at the time to be in an area designated as Offices. The other buildings in the park appear to be similar in use although the two nearest sites at the moment appear unoccupied, one of which is advertised for sale/rental (Millennium House).
• 2.2 The site lies within an area designated on the adopted development plan for the area the Area Plan for the East (2020) - as Industry - Business Park. Business Parks are discussed within the Area Plan Written Statement as follows:

• 8.5.1 There are a number of existing (established) industrial estates and business parks which include smaller vacant plots and areas. These were originally identified and recorded in the Site Identification Report (during the Preliminary Publicity Stage)

• as ‘Site Assessment Framework (SAF) Category 1 Sites’. This label meant that given their size, nature and surrounding land use there was no real policy decision that needed to be made as part of the plan process and it was appropriate simply to colour wash these areas on the maps to reflect the wider land use. A purple ‘hatch’ or colour wash represents industrial land. Sites identified as SAF Category 1 and under 0.35 hectares are not specifically shown on the Proposals Map and Inset Maps.

• 8.5.2 The ELR suggested that the demand appeared to be for smaller employment sites (under 0.25 ha) with some limited demand for larger sites (up to 0.75 ha). It was noted that the development of smaller sites can prove difficult as the shape and size of such sites can reduce flexibility for users. Furthermore, although there was recognised demand for smaller units, development often took the form of a single larger unit which incorporated a number of smaller units.

8.6.2 The Inspector noted in the Inquiry Report (2019) that - “In the circumstances, I consider the provision made for employment land in the draft area plan to be ample” (Para 103). The Report did go on to recommend more land should be moved into General Allocation rather than Strategic Reserve to allow for land assembly, survey work and planning approval to ensure land can be brought forward ahead of 2026 in a phased manner.

• 2.3 There are no specific references to the Victoria Road business park in the document and land has been identified for further such development elsewhere within the plan area.
• 2.4 Business Parks are defined in the Strategic Plan as follows:

Business Parks A development encompassing land for light industrial purposes, warehousing, new technology companies involved in scientific, commercial, or industrial research or development and office accommodation as the corporate headquarters of companies having multiple and diverse interests (but excluding financial/professional services to visiting members of the public); buildings should be set in parkland which should dominate the landscape.

• 2.5 Neither the Strategic Plan nor Area Plans discuss the provision of private health care facilities in particular. The Strategic Plan discusses health care briefly and generally as follows:

10.11 Community Health Care Facilities 10.11.1 Health care facilities such as nursing homes, residential homes, or training centres are usually sited within residential areas, but can generate activity and traffic which has detrimental effects on the amenity and character of these areas. The following policy is therefore adopted.

Community Policy 6: New community health care facilities and extensions to existing facilities will be permitted provided that they:

• a) would not result in an over concentration of such uses in a particular area;
• b) would not have an unacceptable effect on the residential or prevailing character or amenity of the area;
• c) would be easily accessible; and
• d) would not have an unacceptable impact on the local highway network.

Regard should be had also to the parking standards set out in Appendix 7.

• 2.6 Appendix 7 sets out parking standards and advises that for medical/health services 3 spaces per consulting room plus staff parking should be provided.
• 2.7 The delivery of care and medical services is considered to be

Class 4.1 – Clinics or health centres Use as the purpose of a clinic or a health centre (excluding purposes which fall into class 1.2).

Class 1.2 is Financial and professional services Use, where the services are provided principally to visiting members of the public, for the purpose of providing —

• (a) financial services (including the services of a bank, building society or insurance broker);
• (b) professional services (including estate agency, dentist, opticians and legal or architectural services); or
• (c) any other service which it is appropriate to provide in a shopping area, (including a booking office for a driving school or a job centre).

• 2.8 Hospitals are classed as 3.2 along with nursing homes and residential institutions:

Class 3.2 – Hospitals, nursing homes and residential institutions Use for the purpose of —

• (a) a hospital or nursing home; or
• (b) the provision of residential accommodation and care to people in need of care. In this class, “care” has the same meaning as in class 3.1, ie In this class, “care” means personal care for persons in need of personal care by reason of old age, disablement, past or present dependence on alcohol or drugs, or past or present mental disorder.

• 2.9 None of the trees on or surrounding the site is Registered, the site is not within a Conservation Area and does not contain any Registered Buildings. The site is not shown as

being at risk of flooding and there are not understood to be any particular other constraints applicable to the site.

• 2.9 Development is generally directed to sustainable locations within existing settlements as set out in Strategic Policies 1, and 10, Spatial Policy 5 and Transport Policy 1. Strategic Policy 1 also states that:

Development should make the best use of resources by:

• (a) optimising the use of previously developed land, redundant buildings, unused and under-used land and buildings, and reusing scarce indigenous building materials;
• (b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space(1) and amenity standards; and
• (c) being located so as to utilise existing and planned infrastructure, facilities and services.

3.0 The Proposal

• 3.1 Proposed is the change of use of the building from Offices to a private health care facility

• (Class 4.1) including overnight accommodation for patients (Class 3.2). The layout shown in the submitted plans which illustrates a typical facility of this type and how it could be accommodated within the building, includes 13 consultation rooms, 15 day beds, 5 reception areas and a number of specialist areas - radiology, Xray theatre, surgical areas, laboratories etc. This is a typical layout and the actual internal arrangement should permission be granted, may differ in detail but be generally as shown.

• 3.2 The proposed internal layout would see the ground floor providing medical theatres, consultation and treatment rooms, patient bedrooms, staff facilities including a small cafeteria for those using the premises, and toilets. A small shop is shown to provide items which patients might need as well as a dispensary for patients who are being or who have been treated on site. There are separate entrances/exits for staff and for customers to enhance the privacy of those visiting the facility.
• 3.3 The first floor will provide further medical facilities including MRI, CT, radiology, X ray facilities, blood clinic, laboratory, laundry, consultants’ changing facilities, toilets therapy facilities and further overnight accommodation rooms. Many of the facilities on both floors will be used by those patients who are also staying overnight although some will be used by day patients only.
• 3.4 Many patients who stay overnight may not arrive and leave in their own vehicles and will be dropped off and collected, depending upon their condition and treatment.
• 3.5 The site currently has 88 parking spaces within its curtilage and a secure cycle store for staff or customers who wish to cycle to and from the site. Vertical stands will be fitted within the existing store so as to accommodate approximately 24 cycles. Accessible spaces are to be provided which will reduce the overall number to 83. Provision will also be available for the charging of electric vehicles if required. It is estimated that there would be a maximum of around 31 staff on site at any one time as many of the consultation, therapy and treatment facilities will be used by the same staff with a number of staff covering different responsibilities and may be involved in a number of different treatments in different rooms. The number of customers on site at any one time is likely to be around 35.
• 3.6 The site is close to a frequent bus service on Victoria Road.

• 4.0 PLANNING ASSESSMENT

• 4.1 Principle of the proposed use

• 4.1.1 The designation of the site as Business Park brings with it a presumption that the uses within it will be as defined in the Strategic Plan. These do not specifically include medical facilities or health care. However, there are no sites known to be specifically designated for such purposes other than the Island’s public hospitals so there are no sites to which such a new proposed use should be directed in land use planning terms. Community Policy 6 suggests that community health care facilities will normally be permitted - without specifying on what type of site - provided that they would not result in an over concentration of such uses in a particular area; would not have an unacceptable effect on the residential or prevailing character or amenity of the area; would be easily accessible; and would not have an unacceptable impact on the local highway network.
• 4.1.2 It is perhaps relevant that permission was granted relatively recently to the change of use from offices to a doctor/dentist/physiotherapy/optometrist facility not far from here (Warwick House, Victoria Road - 18/01149/C). That site was designated for offices on the Douglas Local Plan which was the relevant development plan at the time of that decision, and is now designated as Mixed Use.
• 4.1.3 The issues in the case of that application as identified by the planning officer were:

• • Was the loss of the building from its authorised use acceptable
• • Was the proposed use acceptable for the building and wider area.

• 4.1.4 These are, it is suggested, the critical issues here along with the issues raised in Community Policy 6.
• 4.1.5 In assessing the first issue, it will be relevant to consider whether the premises are presently in use and if not, for how long have they not been used, why not and what efforts have been taken to try and have the building occupied.
• 4.1.6 The building is presently unoccupied and has been for some time despite having been marketed with numerous estate agencies. Millennium House which sits opposite this site is also presently being offered for rent with Black Grace Cowley amongst many other large

• offices, some of which are located much more centrally than is the application site. Snaefell and Centre Houses alongside do not appear to be currently in use.
• 4.1.7 The continued lack of use and maintenance is not considered beneficial for the building or the surrounding area.
• 4.1.8 As the proposed use is not one listed in the many accepted uses within a business park and as it involves visiting members of the public, it could not be considered to comply with that land use designation. However, one of the purposes of Business Parks is to accommodate uses which generate employment. In this case, the private medical facility could employ around 30-40 staff of various professions with additional cleaning staff. The location of the site will also support the adjacent supermarket and is well placed for public transport and within a large concentration of population from a cycling or walking perspective.
• 4.1.9 For all of the above reasons, we would therefore submit that the site is suitable for the location of a private medical facility despite it not being designated for such purposes.

• 4.2 Impact of the proposal on highway safety, accessibility, sustainable transport and car parking

• 4.2.1 The existing building has a nett office floor area of around 2248 sq m. This results in a car parking requirement using the 1 space per 15 sq m standard for out of town offices, of 150 spaces. Using the lower town centre standard of 1 space per 50 sq m, 45 spaces would be required. The building has 88 spaces available to it.
• 4.2.2 The proposed use will generate a requirement for parking spaces for staff and customers. In terms of staff, as indicated in paragraph 3.5 above and expanded upon in the Transport Statement provided by the architect, there will be sufficient spaces to accommodate all of the staff who could be present on the site, even if they all chose to arrive

• at once in their own private individual vehicle. The facility will introduce a travel plan which will encourage staff to car share, use public transport and if practicable, cycle or walk to work as any of the adjacent offices would be required and encouraged to do. Whilst the parking standard in the Strategic Plan is 3 spaces per consulting room, plus staff parking, the consulting rooms are unlikely to result in the need for three parking spaces as the consultee would be likely to arrive in one vehicle, even if they brought someone else with them and the consultant is likely to also be working within other parts of the facility.

• 4.2.3 The site is as sustainable and accessible for its staff and customers as it is for the staff of its approved use as offices.
• 4.2.4 We would submit that the proposed use will generate a lesser amount of traffic and car parking demand than does/would the continued use of the site for offices. As such, and as the building exists, the present arrangements for access including visibility splays and road widths within and outwith the site, are considered to be acceptable.

4.3 Impact of the proposal on adjacent land uses and over concentration of healthcare facilities in the area

• 4.3.1 Eastfield which sits to the north west of the business park provides public sector facilities for people with learning difficulties. Other than that, there are no other health care facilities in the area and no private hospital facilities as are proposed, currently on the Island.
• 4.3.2 As such, it is not considered that if this application were permitted that there would be an over concentration of this sort of use in the area.

4.4 Suitability of the building for its approved use

• 4.1 The location of the site is considered suitable for the proposed use for reasons set out in section 4.2 above. In addition, the users of this facility are likely to appreciate some discretion in terms of their use of the facility and as such, a setting in a residential area is not considered ideal. In addition, the need for an amount of car parking is relevant as many clients may not be able to easily use public transport when they leave the facility after treatment, or indeed may not choose that form of transport.
• 4.2 The site is discrete, being off the main highway and with relatively few other users of the estate, even were all of the buildings fully occupied. The site has ample car parking and is close to a bus route should that form of transport be required for staff or customers.
• 4.3 As is demonstrated by the proposed plans, the building can be converted to accommodate the proposed use without any external changes and is the appropriate size and layout. It will enable separate accesses for staff and customers and has bicycle storage already on site.
• 4.4 We consider that the building is eminently suitable for the proposed use.

4.5 Impact on the character of the area

4.5.1 The approved use of the site would generate a large number of people coming to the site and then leaving again at the end of the working day with the car park generally utilised throughout the day although there is no control over the operating times of the offices and when its staff can come and go.

• 4.5.2 What is proposed will change that in that people will be coming and going in smaller numbers and throughout a longer working day and over the weekend. As the site is not within a residential area, this longer period of comings and goings will not affect any adjacent residential properties and as the adjacent offices are not likely to be heavily used, or used at all later in the day and over the weekend, this will not have an impact on them either. Indeed, even if the offices were occupied at the same time as the operation of the medical facility, the coming and going of people from the application site would not affect those people in these adjacent offices.
• 4.5.3 There will be no change to the external appearance of the building other than a change of signage which will be the subject of a separate application.
• 4.5.4 We would submit that there will be no adverse impact on the character of the area from the proposed conversion and indeed, the use of the building would be beneficial to the appearance of the area which is presently unoccupied and under utilised.

4.6 Need for the facility

• 4.6.1 At present, private healthcare is administered at the Island’s public hospital, Nobles. There are private wards within the hospital and private healthcare is also provided within the public parts of the hospital.
• 4.6.2 Whilst there are satellite hospitals which can offer some health services including overnight stays, the main concentration of facilities is at Nobles.
• 4.6.3 There is a finite amount of accommodation and facilities at Nobles Hospital with the private facilities often given over to public health care due to a lack of space. Many people who seek private health care go elsewhere, usually to the UK for treatment due to a lack of facilities or long waiting times for treatment on Island.

• 4.6.4 The proposed private medical facility will provide additional space for private treatment, releasing space at Nobles for those requiring treatment provided by the public sector (Manx Care). The proposal is not in conflict with the existing services provided but would rather complement them and free up space and facilities. With a high proportion of the Island’s population already holding private medical insurance, there is a strong, established market for private healthcare provision. Patients may be introduced via insurers, established referral networks, or other healthcare providers, allowing Island residents greater access to a broader range of treatment pathways without the need to travel off-Island
• 4.6.5 The facility, once fully operational, will provide significant additional elective capacity across outpatient diagnostics, day-case procedures, and inpatient care. This will complement existing healthcare infrastructure on the Island and create greater resilience in the delivery of medical services. A proportion of the hospital’s capacity may, subject to agreement with the operator, be made available to other parties, subject to agreement.
• 4.6.6 By increasing capacity and enabling structured collaboration with existing public services, the proposed facility will offer residents greater flexibility and choice in their healthcare options.
• 4.6.7 Beyond meeting domestic demand, the development positions the Island to capture a share of the growing health tourism market. The Isle of Man’s reputation for high standards, safety, and accessibility provides a strong platform from which to attract overseas patients seeking high-quality medical care in a well-regulated, discreet, and accessible jurisdiction.

• 5.0 CONCLUSION
• 5.1 Whilst the site is not designated for the purposes which are proposed for it, it is clear from the Strategic Plan that healthcare facilities may be provided in areas not designated for such - usually residential areas. In this case, the nature of the facility - accommodating larger numbers of people than would be the case in most residential areas - a business park setting is considered suitable in this case.
• 5.2 The site is sustainable, within convenient and safe walking and cycling distance of a large concentration of population and close to a bus route. The site has adequate car and cycle parking provision and could be converted to the proposed use without any external change to the building.
• 5.3 The site is relatively discrete for its intended clientele and its use as proposed would not affect the operation of the adjacent offices.
• 5.4 The building is presently unoccupied and like Millennium House alongside, does not appear to be in demand for its approved use as offices. The continued lack of use and occupation is not favourable either to the building itself or the attractiveness of the surrounding area for occupation and investment. Strategic Policy 1 is clear that development should make the best use of existing resources including optimising the use of unused land and buildings. In this case the building is unused and what is proposed could be accommodated without major change or adverse or significant impact on the area.
• 5.5 The provision of additional private health care facilities would be of benefit to the Island, freeing up space and facilities within the Island’s public hospitals whilst in this case being relatively close to the main hospital for staff who may assist in both facilities.
• 5.6 We would submit that the benefits of the proposed use as set out within this statement outweigh any issue with the land use designation of the site, noting again that there are no sites designated for health care development where such facilities could be created.

Sarah Corlett 27.08.25