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PLANNING OFFICER REPORT AND RECOMMENDATIONS
Application No. : 25/90009/B Applicant : Mr Jason Elliott Proposal : Erection of purpose built self storage facility over two levels with associated car parking and fencing (amendments to 24/00674/B including installation of goods lift, relocation of fencing, installation of timber cladding and signage to north-west elevation) Site Address : Plot 8 Middle River Industrial Estate Pulrose Road Douglas Isle Of Man
Planning Officer: Paul Visigah Photo Taken : 04.09.2024 Site Visit : 04.09.2024 Expected Decision Level : Officer Delegation
Recommendation
Recommended Decision:
Permitted Date of Recommendation: 05.03.2025 __
Conditions and Notes for Approval C : Conditions for approval N : Notes attached to conditions
C 1. The development hereby approved shall be begun before the expiration of four years from the date of this decision notice.
Reason: To comply with Article 26 of the Town and Country Planning (Development Procedure) Order 2019 and to avoid the accumulation of unimplemented planning approvals.
C 2. The proposed storage containers, as shown on drawing referenced 125/101 Rev F, shall have their front elevation clad in timber and the remaining elevations coloured dark green, and they shall be retained as such thereafter.
Reason: In the interests of the visual amenity of the site and the surrounding area.
C 3. The proposed perimeter fencing along the site boundary and gates, as shown on drawing referenced 125/101 Rev F, shall be coloured grey (similar to the adjoining sites) and retained as such thereafter.
Reason: In the interests of the visual amenity of the site and the surrounding area.
C 4. No items of machinery, equipment, or other goods shall be kept outside of any containers, and all activities shall be undertaken within the containers as shown on Drawing 125/101 Rev F.
Reason: In the interests of the visual amenity of the site and the surrounding area.
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C 5. In the event that the containers hereby approved are not used or required for storage purposes for a period exceeding 12 months, the containers and fencing hereby approved shall be removed and the ground restored to its former condition within 18 months of its last use.
Reason: This approval has been exceptionally approved solely to meet the storage need and its subsequent retention if left abandoned could result in an unwarranted visual impact.
C 6. There shall be no retailing from the storage units.
Reason: For the avoidance of doubt, and to ensure the development takes place in accordance with the approved details.
C 7. Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 2019, the use hereby approved shall be limited to storage.
Reason: For the avoidance of doubt, to ensure the development takes place in accordance with the approved details and in the interest of the local amenity.
C 8. The car parking area hereby approved shall at all times be made available for the parking for visiting customers and shall be retained available for such use. No vehicle may be left overnight within the parking area.
Reason: To ensure adequate parking is provided given the reduction in parking spaces.
C 9. The development shall be carried out in strict accordance with the access arrangements as detailed on drawing number 102 Rev B.
Reason: To ensure that all access arrangements comply with the approved drawing and maintain road safety and highway network efficiency.
C 10. Prior to the commencement of development, the flood mitigation measures approved under the Correspondence from the Applicant's Agent received 01 July 2024 (as part of PA 2400674B) shall be implemented in full and retained as such thereafter.
Reason: To safeguard the amenities of prospective occupiers and ensure the development complies with Environment Policy 10 of the Strategic Plan.
C 11. Prior to the occupation of the development hereby approved, the bin storage and recycling collection points shall be provided in accordance with the approved plans (Drawing No. 125/101 Rev F) and shall be permanently retained thereafter and solely for the purpose of refuse storage.
Reason: In the interests of the appearance of the development and the amenities of the area.
C 12. No external lighting shall be installed unless in accordance with the details contained in the Proposed Lighting Plan (Drawing No 105 rev A) and shall be retained as such thereafter.
Reason: To avoid and mitigate ecological impacts.
C 13. The bat and bird boxes proposed as part of the development shall be installed in accordance with the Wildlife Mitigation Measures shown on Drawing No. 104 and retained as such thereafter.
Reason: In the interests of enhancing biodiversity within the site and the surrounding area.
This application has been recommended for approval for the following reason.
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This application has been recommended for approval for the following reason. Overall, it is considered that the proposal would comply fully with the zoning of the site which is for industrial use, and the overall proposed use is in keeping with the layout and general character of the site. It is also considered that the proposal by reason of the location, the availability of parking spaces and acceptable amenity impact on the neighbouring properties is acceptable. The development is, therefore, considered to comply with the requirements of Strategic Policies 1, 5, and 10, General Policy 2, and Transport Policies 4 and 7 of the Strategic Plan.
Plans/Drawings/Information;
This decision relates to the following documents and plans:
o Cover Letter o 125/100A - Location Plan and site Plan o 125/101F - Proposed General Arrangement o 125/102B - Proposed visibility Splay o 125/103B - Proposed Street Elevation o 125/105A - Proposed Lighting Plan o 125/104 - Wildlife Mitigation Plan o Goods Lift Specification __
Right to Appeal
It is recommended that the following organisations should NOT be given the Right to Appeal: o DOI Highways - as they have no objections o DOI Highways Drainage - as they have no objections o Douglas Borough Council - as they have no objections __
Officer’s Report
1.0 THE SITE 1.1 The application site is a parcel of land which lies at the southern side of Middle River Industrial Estate, and beside the former Eastern Civic Amenity Site, situated on the southwestern side of the estate, and at the end of the primary road that serves the estate. The south-eastern boundary of the site bounds mature landscaping and trees, with the mature trees which run along the western edge of the main road serving the estate screening the site from the surrounding Douglas Golf Course on Pulrose Road which sits opposite the site.
1.2 There are vertical bar railings form the boundary of the site with the former Eastern Civic Amenity Site to the south-west, as well as Plot 7 which sits northeast of the site. The site area is generally flat and currently covered in wild grass.
2.0 THE PROPOSAL 2.1 Planning approval is sought for Erection of purpose-built self-storage facility over two levels with associated car parking and fencing (amendments to 24/00674/B including installation of goods lift, relocation of fencing, installation of timber cladding and signage to north-west elevation).
2.2 The proposed scheme involves the erection of two floors of shipping containers on the site, measuring approximately 46.3m along the northeast elevation (its longest side) and 31.6m along the rear (southeast) elevation. The layout includes four rows of shipping containers, each measuring 6.58m in length, separated by corridors measuring 2.7m, 1.8m, and 2.7m respectively. The elevation adjacent to the estate road spans about 15m, featuring two rows of
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shipping containers divided by a 2.7m-wide corridor. To enhance the facility's appearance, the front elevation of the shipping containers will be clad with timber.
2.3 The structure will reach approximately 5.3m in height, measured from ground level to the top of the upper floor. A centrally positioned goods lift will serve the storage spaces on the first floor. Additionally, industrial-style fencing will enclose the site perimeter, with the new fencing relocated forward to sit immediately behind the visibility splay, addressing concerns about potential misuse of the space in front of the site.
2.4 There will be one large automatic vehicular gate installed along the front elevation, operated via a pin pad, alongside a single pedestrian maintenance gate at the rear of the site.
2.5 The revised scheme creates a storage floor area of approximately 1492.8sqm (about 58.2sqm smaller than the previously approved scheme. Based on the Strategic Plan parking requirement of 1 space per 100sqm of gross floor space for storage and distribution, the site would require approximately 15 parking spaces. However, 12 parking spaces are still provided on site as with the previous scheme.
2.6 The key difference between the previously approved scheme and the current scheme are as follows: a. Timber Cladding and Signage: The new plan includes timber cladding on the front elevation of the storage containers to improve aesthetics, along with the addition of site signage. The site signage will, however, not be assessed as part of this application. This detail was not part of the original proposal. b. Reduction in Storage Units: The number of storage units is reduced from 106 to 102 in the updated plan, and floor area from 1551sqm to 1492.8sqm. c. The change accommodates the inclusion of a centrally placed goods lift. d. Relocation of Perimeter Fencing: o The fencing has been moved forward in the updated plan. o Instead of its previous proposed position, it is now immediately behind the visibility splay. This change addresses concerns about potential misuse of the vacant space (e.g., abandoned vehicles or vehicles for sale).
2.7 The following details which were provided in the Planning Statement for the previous application (PA 2400674B) are still applicable to the current application: 1. The running of the storage facility is to be operated mostly remotely and there are no plans to have any permanent staff on site, however maintenance staff would be attending the site, along with office-based staff working from another location. 2. The current facility in Jurby is providing employment for 3 members of staff, and should this expansion be permitted this number is likely to increase. 3. The current leasing records show that the facility would be providing storage facilities to several Retail, Construction/Tradesmen, Commercial Offices, Digital Entertainment, Event management companies and Fitness companies. 4. The provision of car parking spaces relies on the "Self-Storage Association United Kingdom" document (Appendix B) "Traffic Patterns for Self-Storage".
2.8 As part of the scheme's wildlife mitigation measures, the following provisions will be installed on the rear elevation of the units, adjacent to the trees: 1. One Low Profile WoodStone Bat Box from NHBS, or similar approved. 2. Two Vivara Pro WoodStone Swift Nest Boxes from NHBS, or similar approved. 3. Two Vivara Pro Build-In Half Open Nest Boxes from NHBS, or similar approved. These measures aim to enhance habitat opportunities for bats and birds, in alignment with ecological recommendations provided for the development.
3.0 PLANNING POLICY 3.1 Site Specific:
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3.1.1 The site lies within an area designated as Industrial on the Area Plan for the East (Map 4 - Douglas), and the site is not within a Conservation Area. The site is largely not within a flood risk area, although the north-western section of the site has high likelihood of surface water flood risks. There are no registered trees on site, and the site is not within a Registered Tree Area.
3.2 Area: TAPE (2020) 3.2.1 The following parts of the Area Plan for the East are considered relevant: 1. Employment Recommendation 1: A cross-government study could be carried out to identify opportunities to improve the management of existing Industrial Estates to minimise vacancy rates and to also identify opportunities to facilitate investment in new sites (including through the development of a Technology Park(s). 2. Employment Recommendation 2: In the implementation of Employment Recommendation 1, consideration should be given to the identification of areas where: a) uses should be restricted to light industrial uses; or b) areas where 'bad neighbour' uses might be appropriate and consider the merits of safeguarded such areas for these uses.
3.3 National: STRATEGIC PLAN (2016) 3.3.1 Relevant Strategic Plan Policies: 1. General Policy 2 - General Development Considerations. 2. Strategic Policy 1 - Efficient use of land and resources. 3. Strategic Policy 2 - Priority for new development to identified towns and villages. 3. Strategic Policy 5 - Design and visual impact. 4. Strategic Policy 6 - Major employment-generating development should be located in existing centres on land zoned for such purposes and identified as such in existing Local or new Area Plans. 5. Strategic Policy 7 - Undeveloped land which is zoned in Local or Area Plans for industrial, office, or retail purposes will be retained and protected for such uses, except where those uses would be inappropriate or incompatible with adjoining uses. 6. Strategic Policy 10 - development should promote integrated journeys, minimise car use and facilitate other modes of travel. 7. Transport Policy 7 - Parking considerations/standards for development. 8. Business Policy 1 - The growth of employment opportunities throughout the Island will be encouraged provided that development proposals accord with the policies of this Plan. 9. Environment Policy 22 - deals with vibration, odour, noise and light pollution in relation to nearby properties. 10. Environment Policy 4 - protects biodiversity (including protected species and designated sites). 11. Transport Policy 1 - Requires new development to be close to existing public transport facilities and routes, including pedestrian, cycle and rail routes. 12. Transport Policy 4 - New and existing highways which serve any new development must be designed to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan. 13. Transport Policy 7 - Parking standards. 14. Other policies within the Strategic Plan which are considered relevant in the assessment of the proposal are Infrastructure Policy 5, Community Policy 11, Community Policy 7 and Community Policy 10. 15. Paragraph 9.2.4: Sites identified as suitable for Industry will generally also be suitable for the storage and distribution of goods, although, depending upon location with respect to other uses, the Department may restrict the goods stored by attaching the following condition:
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"The building(s) hereby approved may be used for storage and distribution. Approval does not extend to the use of the site for retail purposes or as a skip transfer station or for the storage or distribution of dangerous goods (as defined in the Road Traffic Act: Road Vehicles carrying Dangerous Goods (Maintenance and Use) Regulations 2000) or coal or items which could give rise to nuisance to adjacent land users by virtue of dust, noise or smell".
4.0 OTHER MATERIAL CONSIDERATIONS 4.1 Section 68 of the Flood Risk Management Act (2013) indicates that any published Flood Risk Management Plan and the extent to which the proposed development creates an additional flood risk are material considerations.
4.2 The Isle of Man's Biodiversity Strategy (2015 - 2025) 4.2.1 The Department's Biodiversity Strategy is capable of being a material consideration. It seeks to manage biodiversity changes to minimise loss of species and habitats, whilst seeking to maintain, restore and enhance native biodiversity, where necessary.
4.3 Traffic patterns for self-storage: Self Storage Association United Kingdom 4.3.1 On average there are less than 7 cars per 100 units, entering a site over the whole day. With customers staying an hour on average, most sites would only ever have 2 or 3 cars per 100 units on site at any given time.
4.3.2 There are rarely "visitors" to self-storage facilities. Self-storage units are not usually used for retail sales. While they can be used for storage of commercial goods, they are not sales offices' or administrative units. In fact, most do not even have power to the units. This means there are no "visitors" to the site other than prospective customers. Vehicles within the site are primarily either loading or unloading goods.
4.3.3 Average vehicles entering per day during the regular access hours by centre size and immediate market area: o Number of self-storage spaces: Less than 100 o Average Vehicles per day: 6.5
4.3.4 Average vehicles entering per day during outside of the regular access hours by centre size and immediate market area: o Number of self-storage spaces: Less than 100 o Average Vehicles per day: 2.1
5.0 PLANNING HISTORY 5.1 The site and the adjoining industrial sites were granted approval under PA 98/01395/B for Industrial site layout of roads, plots and sewers, Phase II. This application was approved by the planning committee in November 1998.
5.2 Planning approval was recently granted for Erection of purpose-built self-storage facility over two levels with associated car parking and fencing under PA 24/00674/B. The current scheme varies slightly from this scheme as it introduces timber cladding on the front elevation of the storage containers, reduces the number of storage units from 106 to 102 to accommodate a centrally positioned goods lift, and moves the perimeter fencing forward to sit immediately behind the visibility splay, addressing concerns about misuse of the vacant space in front of the site.
6.0 REPRESENTATION Copies of representations received can be viewed on the government's website. This report contains summaries only.
6.1 DOI Highways Division have indicated that the proposal raises no significant road safety or highway network efficiency issues. Accordingly, Highways Services Development Control
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raises no objection to the proposal subject to all access arrangements to accord to drawing no. 102 Rev B (31 January 2025):
6.2 DOI Highways Drainage has advised that allowing surface water runoff onto a public highway would violate Section 58 of the Highway Act 1986 and guidance in section 11.3.11 of the Manual for Manx Roads. They recommend that the applicant ensures compliance with these clauses (3 February 2025).
6.3 DEFA Ecosystem Policy Team have made the following comments on the application (6 February 2025):
6.4 DEFA Inland Fisheries Development Manager has not made any comments on the application although consulted on 10 January 2025.
6.5 MU Electricity have not made any comments on the application although they were consulted on 10 January 2025.
6.6 Douglas Borough Council has no objection to the application (17 January 2025).
6.7 No comments have been received from neighbouring properties.
7.0 ASSESSMENT 7.1 The main issues to consider with the current application are: 1. Visual impact/impact on the wider environment (EP 22 and GP2 b, c & f); 2. Impact on the neighbouring amenity (GP2g & EP 22); 3. Impact on the highways & parking (TP4, TP6, TP7, GP2 h & i, SP10); 4. Impacts on Biodiversity (EP 4 and GP2); and 5. Flood concerns (EP 10, EP 13 & GP 2)
7.2 The principle of the proposed development has already been deemed acceptable in the previous application, with no changes in policy or site circumstances requiring further review. The site, zoned for industrial use, is consistent with the surrounding estate's character and aligns with Strategic Policy 6, which supports employment-generating developments on appropriately zoned land. Additionally, the proposal meets Business Policy 1 by offering potential employment opportunities. Its proximity to a key employment area in Douglas, with access to labour and an integrated transport network, further strengthens its compliance with Strategic Policy 6. The scheme also optimizes unused industrial land, fulfilling Strategic Policy 1's aim of resource efficiency. On this basis, the principle of the development remains acceptable.
7.3 Visual Impact/impact on the wider environment 7.3.1 The revised scheme maintains the unique design of stacked shipping containers linked by interconnecting walkways but introduces several changes aimed at improving the overall visual impact and functionality. The reduction in the number of units from 106 to 102 has allowed for the inclusion of a centrally positioned goods lift, enhancing accessibility and usability. Additionally, the front elevation now features timber cladding, which softens the industrial appearance of the containers and improves aesthetic integration with the surrounding estate. The height remains consistent with the previously approved application, staying below the eaves level of the adjacent building to the north, ensuring proportionality within the industrial landscape. The crinkled profile of the containers also continues to align visually with
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the industrial cladding found on nearby buildings, maintaining harmony with the character of the area.
7.3.2 Another notable improvement is the relocation of the perimeter fencing to a position directly behind the visibility splay, addressing previous concerns about potential misuse of the vacant space. This adjustment further enhances continuity with the roadside appearance of adjoining sites, contributing positively to the estate's overall visual cohesion. On balance, the alterations refine the scheme, improving its appearance and integration without compromising its industrial function. The revised proposal remains consistent with policies GP2 (b & c) and EP42, and a condition will ensure that the fencing colour matches the surrounding street scene, further supporting its acceptability in the wider environment.
7.4 Impact on adjacent properties 7.4.1 The proposed revisions to the scheme do not alter the previously assessed impacts on neighbouring properties, as the key concern remains the potential activity on site. The storage use is inherently low-impact and does not interfere with the operations of adjacent buildings, especially since it is served by its own access via the internal link road. Additionally, the proposal is expected to generate low visitor volumes, consistent with the nature of self-storage facilities of this size, averaging 13.1 vehicular visits per day. This minimal activity ensures there would be no detrimental effect on existing businesses in the estate, which typically experience higher visitor numbers. Therefore, the revised scheme remains compatible with the industrial character of the surrounding area and complies with policies GP2g and EP22.
7.5 Impact on the Highways and Access 7.5.1 The revised scheme maintains a parking provision of 12 spaces, despite the reduction in floor area from 1551sqm in the previously approved scheme to 1492.8sqm and a reduction in the number of storage units from 106 to 102. While this provision results in a shortfall of 3 spaces based on the Strategic Plan requirement of 1 space per 100sqm gross floor area, it is important to note that DOI Highways previously considered the parking provision acceptable for the larger floor area and higher number of units in the earlier proposal.
7.5.2 Similarly, the parking provision falls short of the UK self-storage parking guidance, which recommends 13.1 parking spaces for facilities with 100 to 299 units, leading to a shortfall of 1 space. However, as the revised scheme reduces the scale of development, the parking impacts remain less significant than in the approved scheme, further supporting its sufficiency.
7.5.3 The access arrangements whilst changed slightly from the previous scheme would still provide for smooth vehicular movement into and out of the site, ensuring that no tailing traffic is pushed onto the adjacent highway. Moreover, the new fence line placement retains the visibility for the access, and the neighbouring plot currently has no direct access on this side of the plot where visibility could be impacted. As well, the alteration has created some additional movement space internally, particularly to units in the north-east side which improves safety within the site.
7.5.4 Further to the factors highlighted above, DOI Highways have reviewed the revised proposal, and consider that the proposal raises no significant road safety or highway network efficiency issues, although they request that all access arrangements to accord to drawing no. 102 Rev B. therefore, it is considered that the proposal continues to align with the aforementioned transport policies within the Strategic plan, such that the parking and highway elements are considered acceptable.
7.6 Impact on biodiversity 7.6.1 Under the previously approved scheme, the ecological impacts of the proposed development were assessed based on ecological information reviewed and accepted by the DEFA Ecosystems Officer. It was concluded that the application satisfied the principles of
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Environment Policy 4, subject to conditions requiring the implementation of mitigation measures.
7.6.2 Further ecological information has now been provided in the revised scheme, including specific wildlife mitigation measures to enhance habitat opportunities for bats and birds. These measures include the installation of one Low Profile WoodStone Bat Box, two Vivara Pro WoodStone Swift Nest Boxes, and two Vivara Pro Build-In Half Open Nest Boxes, or similar approved alternatives, all to be installed on the rear elevation of the units, adjacent to the trees. These additions represent an enhancement to the original scheme and further demonstrate compliance with Environment Policy 4, reinforcing the ecological value of the development. Conditions will again be imposed to ensure these measures are fully implemented.
7.7 Flood concerns (EP 10, EP 13 & GP 2) 7.7.1 Although DOI Flood Risk Management (DOI FRM) has not provided comments on the revised scheme, the proposal involves a reduction in scale compared to the previously approved application. The decrease in gross floor area from 1551sqm to 1492.8sqm, along with the reduction in the number of storage units from 106 to 102, results in less surface coverage and activity on-site. These changes inherently reduce the potential impact associated with surface water flooding, indicating an improved condition over the previous proposal.
7.7.2 The larger, previously approved scheme included detailed flood mitigation measures that were accepted by DOI FRM. These measures remain applicable to the current proposal, providing effective protection against flood risks. With the reduced scale of the development, the same mitigation strategies are expected to offer even greater resilience to surface water flooding. As such, the revised scheme complies with the principles of Environment Policy 10, subject to a condition ensuring the implementation of the previously recommended mitigation measures outlined in the applicant's correspondence dated 1 July 2024. This approach ensures continued compliance with flood risk management requirements.
8.0 CONCLUSION 8.1 For the above reasons, it is concluded that the planning application would be appropriate for the character of the site and area and accords with the aforementioned planning policies of the Isle of Man Strategic Plan 2016.
9.0 RIGHT TO APPEAL AND RIGHT TO GIVE EVIDENCE 9.1 The Town and Country Planning (Development Procedure) Order 2019 sets out the process for determining planning applications (including appeals). It sets out a Right to Appeal (i.e. to submit an appeal against a planning decision) and a Right to Give Evidence at Appeals (i.e. to participate in an appeal if one is submitted).
9.2 Article A10 sets out that the right to appeal is available to: o applicant (in all cases); o a Local Authority; Government Department; Manx Utilities; and Manx National Heritage that submit a relevant objection; and o any other person who has made an objection that meets specified criteria.
9.3 Article 8(2)(a) requires that in determining an application, the Department must decide who has a right to appeal, in accordance with the criteria set out in article A10.
9.4 The Order automatically affords the Right to Give Evidence to the following (no determination is required): o any appellant or potential appellant (which includes the applicant); o the Department of Environment, Food and Agriculture, the Department of Infrastructure and the local authority for the area;
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o any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and o in the case of a petition, a single representative.
9.5 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity, they cannot be given the Right to Appeal. __
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 and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded interested person status, and/or rights to appeal.
Decision Made : Permitted Date : 07.03.2025
Determining Officer
Signed : S BUTLER
Stephen Butler
Head of Development Management
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