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W.B.Vannan DA [Edin.], Dip T&CP Architect & Planning Consultant Cronk-na-Quill Old Laxey Hill Laxey IM47DA tel. [01624] 861013 mob. [07624] 485645
RECEIVED ON 20 JUN 2013 DEPARTMENT OF INFRASTRUCTURE 17th June 2013
Proposed Conversion of Existing Hotel into Eight Apartments, Nelson Hotel, 11 Mona Drive, Douglas, Isle of Man.
This Written Statement sets out the rationale behind the current Application and seeks to address the Reasons for Refusal under PA10/01698 which is clearly of direct relevance to this current Application. In doing so, reference is made to developments in the vicinity which are relevant to this Application.
This is illustrated on the accompanying Drawings Nos. PD-001 and PD-012 from which it can be seen that it is located on a corner site in an area known as the "Drives", some eighty metres from the Douglas Promenade, in what was formerly a major area of tourism based hotels developed during the Victorian era. It should be noted that as a building there are limited outlooks, with views basically of neighbouring properties. There are no sea views apart from glimpses achieved from the Ground and First floor bay windows on the corner of Mona Drive and Empress Drive. The tourism base of this area has however gradually declined, largely as a result of changing tourist trends. The resultant lack of tourist demand has resulted in pressure for demolition or refurbishment and conversion to alternative uses such as residential or offices.
The historic and architectural significance of the area in general, which forms a significant part of the Douglas Promenade and its hinterland has been recognised and as a result designated as a Conservation Area The prime purpose of this Designation is to preserve this character and to introduce appropriate and sympathetic measures for its enhancement and preservation where necessary. Located as it is within a prime situation in the Conservation Area, the Nelson Hotel is therefore subject to those constraints and this Application seeks to conform to its principles by the intention of retaining the building along with the essential measures for the consolidation and maintenance of the structure in order to preserve its usefulness as a functioning entity.
To this end essential internal works have already been carried out which will help to determine the scale and nature of the necessary works
It should however be noted that whilst the above Principles and Policies are those established by Central Government, little in the way of incentives exist in order to assist their implementation.
In particular, financial assistance is not forthcoming to any meaningful extent.
Whilst economic and financial matters are not strictly Planning issues, “Change of Use” is one mechanism which will be a financial encouragement in this proposed development.
Note: It is stated Government Policy to encourage development and employment. The regeneration which would result from this proposal would contribute to this Policy. Evidently any such a Change of Use must conform to the relevant Planning Policies.
The alternative and unacceptable option would be the ‘do nothing’ approach in avoiding carrying out essential maintenance and permitting the building to degenerate into such a condition that demolition and redevelopment would be the only option.
This is clearly not desirable and a replacement building is most unlikely to be successful in contributing to the ambience of the Conservation Area, as can be seen elsewhere in the vicinity.
The current Use is clearly that of Tourism. The adopted Douglas Local Plan [1998] defines the Land Use designation as “Mixed Use – Tourism/Residential Offices. This Application therefore conforms with that designation and the matter of Land Use is not in dispute.
The Nelson Hotel has been the subject of a number of previous Applications in the immediate vicinity. Amongst these, those which are considered to be relevant to the Application Site are:
Note: All of the above were Approved at Appeal.
It is interesting to note the Inspector’s comments contained in his Report on PA 08/01550;
Para. 15. “As is pointed for the appellants, the requirement for flat conversions to have “a pleasant clear outlook, particularly from the principal rooms” stated in Housing Policy 17 of the Strategic Plan is virtually the same as previous policy which applied when other conversion schemes with lower ground floor flats were approved in the Drives area. Therefore it would appear inconsistent to refuse approval for this proposal on grounds relating to the restricted outlook from the front lower ground floor flat.”
2.
Para. 16. Because of the lack of off-street parking provision, the proposal would not meet the normal parking standards set out in Appendix 7 of the Strategic Plan [one space for a one-bedroom flat; two spaces for flats having two or more bedrooms. However the Plan states that the normal standards may be relaxed in certain circumstances, including those where development would secure re-use of a building of architectural or historic interest or would benefit the character of a conservation area.
Note: The above are of particular relevance to the Current Application.
The most recent Application for this site was submitted by the same Applicant. That Application, PA No. 10/01698, was for the conversion of the hotel into eight apartments and was Refused by the Senior Planning Officer on the 15th. February, 2011.
The Applicant did not take the Application to Appeal.
The proposed development would be contrary to Housing Policy 17 of the Isle of Man Strategic Plan 2007 in that:
i] the basement will have a poor residential environment by virtue of its outlook and access to natural light.
ii] the ground floor apartment will have a poor residential environment by virtue of its outlook onto a motorbike/bicycle parking area and use of the parking area will result in overlooking, loss of privacy, noise and general disturbance to that apartment; and
iii] apartments 4,6 and the front apartment on the third floor will have a poor residential environment by virtue of their bedrooms being adjacent to living rooms of the neighbouring apartment which will result in general disturbance and increased noise to the affected apartments.
Land Use.
Response: The proposed Use is compatible with Policy and is therefore not an issue.
Housing Policy 17 is referred to, and refers to the desirability of flats having a pleasant clear outlook.
This however should be balanced against the conversion of redundant buildings, such as hotels, to residential use as advocated in the preamble to Policy 17.
3.
Para.8.13.1 of that document states:
“There are in the Island, and particularly in Douglas, many substantial buildings which, because their size or form, are no longer suitable for the original intended use as either single dwellings or holiday accommodation, but which are still structurally sound.
The Department has for many years encouraged the conversion of such buildings, where appropriate, into flats
Response: This assessment is largely subjective with no comment from the Environmental Officer regarding matters such as daylight aspects and habitation issues.
Previous Applications.
It does not pay heed to an Inspector’s Findings regarding previous relevant Applications [referred to above] and is therefore inconsistent.
The matter of internal space organization is one which is largely influenced by the inherent constraints imposed by the conversion of a hotel dating from the Victorian Period.
Conversely, the greater ceiling heights as opposed to current standards do result in a feeling of greater space whilst the retention of original features such as cornices and other plasterwork and Victorian features also contribute to the impression of quality and good amenity.
The Basement: This is to be retained as existing and used for purposes such as storage and uses ancillary to the building.
Alternative Uses have been examined, including car parking, but have been ruled out due to space, access and impact on the integrity of the building.
It has been accepted by the Applicant that two apartments would be made available under the House Assistance Purchase Scheme in accordance with Housing Policy 5 of the Strategic Plan:
“In granting planning permission on land zoned for residential development or in predominantly residential areas the Department will normally require that 25% of provision should be made up of affordable housing. This policy will apply to developments of 8 dwellings or more.
It has been accepted by the Planning Office that it would be neither realistic nor desirable to provide car parking on site.
The Application Site is however in close proximity to Public Transport and within walking distance of the town centre and local amenities.
However, in the light of the parking problem throughout Douglas it was felt that private, secure provision should be made on site for at least some two wheeled transport in the shape of motorcycles and bicycles.
This approach was agreed during discussion with the Highway Authority and was considered to be desirable. The impact on the relevant ground floor bedroom would be minimal as would be the general outlook from that apartment. In addition it is considered that by comparison to motor vehicles any disturbance would be negligible. It would evidently have been simple to omit this provision altogether.
4.
An Inspector has previously pointed out that discretion in regard to car parking provision may be applied in certain circumstances, including Conservation Areas. This is set out in Appendix 7 of the Isle of Man Strategic Plan, Parking Standards which states:
> “These standards may be relaxed where development: > [a] would secure the re-use of a Registered Building or a building of architectural or historic interest; or > [b] would result in the preservation of a sensitive streetscape; or > [c] is otherwise of benefit to the character of a Conservation Area. > [d] is within a reasonable distance of an existing or proposed bus route and it can be demonstrated a reduced level of parking will not result in unacceptable on street parking in the locality.”
It should also be noted that this Application includes a Parking Survey carried out from 13th. May until 18th. May 2013 Around the Nelson Hotel at No. 11 Mona Drive. This indicates availability of on-street parking in the immediate vicinity.
This Application follows on from a previous one which displayed similar characteristics and thus the Reasons for Refusal have been incorporated and countered in this fresh Application.
The proposal is for the creation of residential units in the form of apartments in the centre of Douglas where a strong demand exists.
In order to provide such accommodation the opportunity has been taken to convert a redundant hotel within a prime Conservation Area of Douglas.
The conversion and rescue of a Victorian building such as this will also present challenges in meeting current day standards whilst being an economically less attractive solution than new build.
A balance should therefore be achieved between the provision of essential housing and the ideal standards without compromising the quality of life of the occupants of those properties.
It is indeed the policy of Government to exercise in its application of standards, and in particular where it is clearly desirable to preserve a particular building, such as that in a Conservation Area.
The same principle may be applied in the application of parking standards where again it is Government policy to apply discretion cases such this Application within a Conservation Area.
Importantly, these Policies have previously been recognised and applied by Inspectors.
Insofar as the disposition of rooms within the building is concerned it should be remembered that these apartments will be of minimal occupancy and thus are unlikely to generate excessive noise.
Such issues fall under separate legislation, namely that of Building Control and the Planning Office should not seek to invoke controls under other legislation.
This Application consists of a Proposal which has examined Reasons for Refusal under a previous Application and used these as the basis of formulating a Scheme which will hopefully respond to possible adverse reaction.
5.
In so doing it is considered that previous Reasons for Refusal have not paid heed to the exercise of discretion under established Planning Policy but have concentrated on justifying refusal.
W.B.Vannan
6.
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