DEC Officer Report

Application No.: 19/00377/CON Applicant: Celtic Investments Limited Proposal: Registered Building consent for internal works and refurbishment of building (in association with 15/00065/CON) Registered Building Nos. 59 Site Address: 3 The Parade Castletown Isle Of Man IM9 1LG Principal Planner: Miss S E Corlett Photo Taken: 22.05.2019 Site Visit: 22.05.2019 Expected Decision Level: Officer Delegation Recommended Decision: Refused Date of Recommendation: 13.11.2020 _________________________________________________________________ Reasons for Refusal R : Reasons for Refusal O : Notes attached to reasons R 1. Proposals to alter Registered Buildings should be developed based on an understanding of what is significant about a building to avoid any unnecessary impact. There are historic elements including cupboards that would be affected by proposed internal wall insulation. It is considered that the application has not identified those important surviving elements of the building, which need to be considered properly when developing proposals of this nature and there are conflicting messages about what materials should be used; assessed whether insulation/tanking is the right approach in this instance given the above advice contained within the HE guidance. As such, it is considered that the proposals fail to accord with Environment Policies 32 and 34 and Planning Policy Statement 1/01 RB/3 and RB/5.

_______________________________________________________________ Interested Person Status – Additional Persons None _____________________________________________________________________________ Officer’s Report THE SITE

1.1 The site is the residential curtilage of 3, The Parade which is one of a number of Registered Buildings which form The Parade - a square of three storey buildings which abut the Market Square which is the heart of Castletown's commercial area. The area also contains the majority of the town's historic fabric with Castle Rushen sitting alongside.

1.2 The application property is one of three buildings which sit on the north eastern side of The Parade. All three are three storeys in height and numbers 2 and 3 are the same height, number 1 being a metre or so higher with slightly higher first and second floor window levels. - 1.3 Numbers 2 and 3 are not identical: number 2 is marginally narrower and has its windows slightly closer together and also has full length windows on the first floor which contrasts with the higher cill levels of those on number 3. The windows on the ground floor of both properties have rounded heads and the flat heads of the windows on the first floor all have pediment type features above the window heads. The properties are smooth rendered to the front. - 1.4 The rears of the properties differ in that number 3 has a three storey pitched roofed annex which sits on the northern side of the rear elevation, almost abutting the boundary with number 2. Number 2 has no such feature. THE PROPOSAL

2.1 Proposed is Registered Building consent for refurbishment of the building. Planning approval was granted under 15/00064/GB and this approval has apparently been commenced. The current RB application involves the following: - 2.2 Study/games room, lower ground floor

• 2.2.1 Removal of all internal stud walling and the original walls checked for water ingress. Existing stone walls to be treated with Vandex slurry tanking up to 1800mm on external walls and up to 1200mm on internal walls with external walls receiving 62.5mm insulated plasterboard on dabs or approved adhesive and skin finished.
• 2.2.2 Removal of existing skirting with retention of non-damaged parts and replacing with new to match.
• 2.2.3 Removal of existing concrete slab floor and the level of the ground below lowered to receive waterproofing, new concrete slab and insulation as shown on the drawings. An insulated floating floor is to be introduced over the waterproofing. The final layer is to be chipboard or plywood to receive the finished flooring as selected by the applicant.
• 2.2.4 All existing doors to be taken off, refurbished and rehung and reusing or replacing damaged architraves.
• 2.2.5 On the other study/games room on this floor, the underside of the ceiling is to be removed and timbers assessed for damage (repair where possible, replacement where not) with new plasterboard and skim finish throughout.
• 2.2.6 The lower floor narrow windows are to be replaced with purpose made casements which open inward and are hinged at the bottom.
• 2.2.7 A former door opening is to be reinstated at the bottom of the stairs into the rear room. This will match the door on the other rooms on this floor.

2.3 Hall and storage

• 2.3.1 Similar works to existing stud walls, skirting, underside of ceiling and flooring. In addition, the stairs are to be checked to see if any repair is required. The existing newel post is to be maintained throughout.

2.4 Ground floor: hall

• 2.4.1 Existing stud and plasterboard lining to external walls is to be removed throughout and the existing stone walls assessment for water ingress. As necessary the walls will be rerendered in lime mortar. A new timber stud wall is to be introduced to create a separate

entrance hallway with glazed doors to open out into the reception room. A new internal doorway is to be created to give access to the study from the hall.

• 2.4.2 An existing suspended ceiling is to be removed to enable assessment of the condition of the structure with a new ceiling installed if appropriate to be fixed to the underside of the joists. Existing coving is to be carefully removed and retained where possible and where not retained, will be replicated to match the existing.
• 2.4.3 The existing laminate floor is to be removed and existing floor boards exposed and assessed for damage and replaced where necessary. The existing door is to be refurbished and painted to match the existing and existing skirting boards are to be removed and reinstated where possible, replaced to match the existing where not.

2.5 Reception room

• 2.5.1 Similar works to the other rooms but including a new timber stud wall erected to create a separate hallway and glazed doors opening into the new reception room. This room is to have new purpose made timber framed Georgian style sliding sashes to match those in number 2 but with the glazing bars in the lower sash reintroduced.

2.6 Study

• 2.6.1 Similar works as to the other rooms with the rear window replaced with a new sliding sash without the weights.

2.7 Rear toilet and utility room

• 2.7.1 Similar works to the above with the retention of the existing window, the application of plasterboard internally and existing architrave and panels retained throughout. A new gas fired boiler is to be introduced to replace the existing.

2.8 First floor: landing

• 2.8.1 Existing walls to be inspected for damage and repaired where necessary with handrails, newel posts, balusters and skirting boards retained where possible and replaced otherwise.

2.9 Dining room and living space

• 2.9.1 Similar works to other rooms with the removal of existing internal stud walls. The windows in the front elevation which are currently sliding sash and with a higher cill than in number 2, are to be replaced to be similar to those in the adjoining building and matching the proportions of those in number 1. These will be timber framed doors with subsidiary glazing bars, similar in style to those in the front of Balcony House opposite but with more detailing. This reflects the fenestration in 1958 (see photograph).

2.10 Kitchen

• 2.10.1 Similar repair and refurbishment works as with other rooms. Windows to be replaced with new double glazed sliding sashes to match the existing but without horns. The existing weights in the windows will be renewed.

2.11 Bathroom

• 2.11.1 Similar work to other rooms including the removal of existing partition walls with new sanitary ware and the retention and refurbishment of the existing window.

2.12 Second floor: landing

• 2.12.1 Existing walls and fixtures to be retained where possible and replication where not.

2.13 Master bedroom and en-suite

• 2.13.1 Works similar to other rooms: new timber framed sliding sash windows to the front elevation to match the existing.

2.14 Bedroom 1

• 2.14.1 Works similar to other rooms. New coving to be introduced to match the other rooms. An existing interconnecting door between the bedrooms will be sealed up and a new opening introduced to the landing.

2.15 Bathroom 2

• 2.15.1 Repair and assessment works as with other rooms with the existing windows retained and refurbished.

2.16 Third floor rooms

• 2.16.1 Assessment, repair and replacement works as with previous rooms. Existing rooflights are to be replaced with a new Conservation style rooflight with dimensions of 550 by 980mm.

• 2.16.2 The chimneys are to have their flashings removed and replaced in lead. New internal doors to be introduced to provide access to under eaves storage.

2.17 External works

• 2.17.1 Existing walls will have their paint removed with an assessment of any damage and allow for re-painting, Repairs to cracked render will be undertaken in lime mortar and other appropriate materials.

• 2.17.2 The fibre cement roof tiles are to be removed and replaced with natural slates with appropriate supporting work beneath.

2.18 The applicant has provided photographs of some of the interior of some of the rooms. PLANNING POLICY

3.1 As the building is Registered, it is appropriate to consider the Strategic Plan and Planning Policy Statement 1/01 - Conservation of the Historic Environment of the Isle of Man. Both of these documents acknowledge the importance of Registered Buildings and require careful consideration of alterations which would adversely affect the character or appearance or any aspect of historical, architectural or other interest which contributed to the Registration of the building. These policies are EP 32, EP34 and RB/3 and RB/5. - 3.2 The site lies within an area of Mixed Use on the Area Plan for the South and within the town's Conservation Area. As such, there is a requirement for development proposals to take account of the special character of the Area and for such to preserve or enhance the Area in accordance with Environment Policy 35 and CA/2. - 3.3 The development should also adhere to the general standards of development set out in General Policy 2 although none of these is relevant to the replacement and refurbishment works which will have no discernible impact on the appearance of the property, its use or the impact on neighbours and those parts which deal with the visual impact are less stringent than the Conservation and RB policies listed above. PLANNING HISTORY

4.1 The property was the subject of two applications in 2015 which are relevant. 15/0064/GB and 15/00065/CON proposed the same external works but some different internal works and where the use was proposed to be changed from office to residential. REPRESENTATIONS - 5.1 Department of Infrastructure Highway Services indicate that they have no highway interest in the application (16.04.19).

5.2 Manx National Heritage express concern that the application does not contain sufficient information regarding justification or architectural appraisal of the age and significance of the

• changes proposed to enable proper consideration of the proposed works. There remains an inconsistency to the materials and detailing. They provide a synopsis of the history of the building, suggesting that the fenestration has changed over time with a more simplified one over one and two over two arrangement being brought in during the Victorian era, replacing the more complex six over nine on the ground and first floor and six over six on the second floor. They suggest that the dormers on number 2 are not original and that there were never any on number 3. Their preference would be to restore rather than repair as found and in this respect the applicant's intention to restore the original window openings is welcome although this should be part of a whole suite of work to restrore the property to the same date throughout. They advise that all original or at least early plasterwork, joinery should be identified and inventoried and they recommend that it may be necessary to first remove all dry-lining, studwork etc to reach a full understanding of the extent and survival of such detailing after which properly informed decisions may be made on the appropriate historical scheme against which to match repairs or replacements. They note in particular that photographs accompanying the previous application show extensive use of a low skirting board with a torus profile which is most unlikely to be historically correct and a search should be made to identify any survivals of a taller skirting board with a more complex ogival profile. These would certainly be more appropriate for the ground and first floor rooms and a shorter board may be appropriate on the second floor. Such records should be made on a consistent room by room basis including scaled photographs and drawings where appropriate or plaster moulding profiles and joinery details and a copy submitted to the Department. MNH would certainly consider accepting a digital security copy for the national archives. Finally, they suggest that the Schedule of Works currently propose minimal repair to the external render and if the openings on the first floor of the front facade are to be opened, consideration should be given to restoring the bead moulding framing the reveals and that paint removal should aim to define more clearly the original scribed lines on the ground floor which are currently rather indistinct (24.05.19).
• 5.3 The Principal Registered Buildings Officer initially provided advice about the scheme but makes the following comments about the submitted application:

The ongoing issue with this application has been a lack of understanding about the elements of the building that are surviving and contribute to the special interest of the building. This issue has been raised by me and MNH me previously, proposals should be developed based on an understanding of what is significant about a building to avoid any unnecessary impact. There are historic elements including cupboards that would be affected by proposed internal wall insulation.

Policy RB/5 in PPS 1 states: "Applicants for registered building consent for alteration or extension to a registered building must be able to justify their proposals. They will be required to show why the works which would affect the character of the registered building are desirable or necessary and they should provide full information to enable the Department to assess the likely impact of their proposals on the special architectural or historic interest of the building and on its setting."

With regards to the attached Historic England (HE) Guidance on solid wall insulation; it is disappointing that the guidance which I had originally given to the applicant at pre-application stage has not been used. This relates to be proposed internal wall insulation and basement tanking. The application talks about using lime as a breathable material to re render the gable (which should in itself go a long way addressing the issues within the property on the said gable wall) but then also wishes to depart from this approach to make part of the building unbreathable.

The following statements are from the HE guidance and are all issues which need consideration in this case;

"Whether applied externally or internally, this type of work (solid wall insulation) can have a significant impact on the appearance of the building. Wall insulation will also alter the technical performance of the solid wall and can either exacerbate existing moisture-related problems or create new ones. In some cases the technical risks of adding insulation to solid walls will be too great and alternative ways of providing a more cost effective long-term solution to improving energy efficiency may be more appropriate."

"When traditional buildings are working as they were designed to, the evaporation will keep dampness levels in the building fabric below the levels at which decay can start to develop. This is often referred to as a 'breathing' building."

"In listed buildings, consent will be required for any internal alterations that affect the appearance and character, including any materials, details and finishes of historic or architectural interest. In many cases this may make the installation of insulation unacceptable."

My concerns are therefore, the application still hasn't identified those important surviving elements of the building, which need to be considered properly when developing proposals of this nature. There are conflicting messages about what materials should be used; assessed whether insulation/tanking is the right approach in this instance given the above advice contained within the HE guidance.

As the application stands I cannot support any proposed solid wall insulation or cement tanking of the basement. We can provide further advice but much more work is required both in understanding the building in terms of significance and the buildings need to regulate moisture." (11.11.20)

ASSESSMENT

6.1 The works must result not only in preservation or enhancement of the character or appearance of the Area but must also protect and preserve any fabric of historic importance or interest. The applicant suggests that the proposal was developed in conjunction with the former Registered Buildings Officer although his later negative comments suggest that not all of his suggestions were fully understood or included in the scheme.

6.2 As noted in paragraph 5.3 there needs to be an assessment of the elements of historic fabric which should be retained and which do not appear to be where these have been recognised. - 6.3 The application has not identified those important surviving elements of the building, which need to be considered properly when developing proposals of this nature. There are conflicting messages about what materials should be used; assessed whether insulation/tanking is the right approach in this instance given the above advice contained within the HE guidance. - 6.4 As the application stands there can be no support for any proposed solid wall insulation or cement tanking of the basement. It is suggested that much more work is required both in understanding the building in terms of significance and the buildings need to regulate moisture.

CONCLUSION

7.1 The works are considered to fail to comply with Environment Policies 32 and 34 and RB/5 of Planning Policy Statement 1/01. INTERESTED PERSON STATUS - 8.1 By virtue of the Town and Country Planning (Registered Buildings) Regulations 2013, the following are automatically interested persons:

• (a) The applicant, or if there is one, the applicant's agent;
• (b) The owner and the occupier of any land that is the subject of the application;

• (c) Manx National Heritage; and
• (d) The local authority in whose district the land the subject of the application is situated. _____________________________________________________________________

I can confirm that this decision has been made by the Head of Development Management in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation.

Decision Made : Refused Date : 16.11.2020 Determining officer

Signed : S BUTLER Stephen Butler Head of Development Management

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