Consultation 4 MNH

Manx National Heritage

Eiraght Ashoonagh Vannin

www.manxnationalheritage.im

Manx National Heritage, Douglas, Isle of Man IM1 3LY Eiraght Ashoonagh Vannin, Doolish, Elian Vannin IM1 3LY

☎: +44 (0)1624 648000 📠: +44 (0)1624 648001 📧: [email protected]

Our Ref: 16/00654/CON

5th June 2017

Ms E J Callow Secretary to the Planning Committee Department of Environment, Food and Agriculture Murray House Mount Havelock DOUGLAS IM1 2SF

Dear Ms Callow

PA 16/00654/CON: De-registration of Woodlands (RB190) in accordance with Section 7(1)(a) of the (Registered Buildings) Regulations 2013, Woodlands, Alexander Drive, Douglas

I write on behalf of Manx National Heritage ('MNH'), whose statutory responsibilities pertaining to the protection of the cultural and natural heritage of the Isle of Man are defined under the terms of the Manx Museum and National Trust Act. The following comments are also submitted under the terms of Sections 8 and 9 of the Town and Country Planning (Registered Buildings) Regulations 2013, in which Manx National Heritage is named as a consultee.

We note that the above application is fundamentally contrary to Environment Policy 31 of the Strategic Plan 2016, which states that "There will be a presumption against the removal of any Registered Building from the Register." MNH strongly supports both the original decision to register this property, and the intent of Environment Policy 31.

In considering the applicant's five written reasons for requesting the de-registration of the property, we would comment on them as follows:

1. The "1987 agreement" would appear to refer to the Convention for the Protection of the Architectural Heritage of Europe, known as the Granada Convention (opened in 1985 and signed by the UK in 1987). We are not aware of a specific action by the Isle of Man which "breaks" this agreement.

1. We similarly are not aware of any such notification and as a consequence of our response to (1) above do not believe that such a notification would be in order.

1. We are not sure what is meant by "a lack of enthusiasm", nor by "Baillie Scott desecration". Whilst a Conservation Officer has not been in post for two years (the position has since been filled), the Planning Office has continued to provide advice to applicants and owners, and has sought the views of MNH where relevant. Although the applicant is not specific, we note that the Planning Committee refused planning permission for The Red House (though the decision was overruled at appeal), and that the appeal against permission for Leafield/Braeside was successful.

1. All buildings require maintenance. The provisions of Planning Policy Statement 1/01, Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man, make it clear that maintenance is the responsibility of the property owner.

Manx National Heritage is the Registered Business Name of the Manx Museum & National Trust which operates under its own Act of Tynwald and is Registered Charity No. 603 in the Isle of Man.

The applicant would have been made aware of the property's protected status at the time of acquisition, and indeed has acknowledged this when preparing planning applications since. The Planning Policy Statement goes on to state that, "works to protect the structural integrity..., or ... the architectural and historic interest of the building, may well merit financial assistance under one of the prevailing financial assistance schemes.... Each case will be judged upon its individual merits." We would comment that whilst it is the case that there is no current assistance scheme in place, the Policy makes it clear that the applicant could not reasonably assume such assistance would be forthcoming in any event.

1. The Isle of Man has extensive legislation, policy and regulation relating to the built environment, which continues to be enforced by the Planning Office. MNH also provides professional advice and guidance, and comments as appropriate on individual planning applications. In the light of this we would not consider this reason sustainable.

In our view the applicant has not provided any justifiable reason why the property should be removed from the protected buildings register, and we would therefore recommend that the application be refused.

We trust that the above comments are of help to the Planning Committee in reaching a decision.

Yours sincerely

ACC Johnson Inspector of Ancient Monuments

cc Mr S. Moore, Building Conservation Officer