Bulky Goods Planning Support Letter

Les Stephan Planning Ltd

Chartered Town Planners & Development Consultants

9 Sweetlake Business Village · Longden Road · Shrewsbury · SY3 9EW Telephone: (01743) 231040 · Fax: (01743) 243490 Email: [email protected]

0900229

The Planning Committee Our Ref: DNW/AYP/1266 Department of Local Government & the Environment Murray House Mount Havelock Douglas IMI 2SF

RECEIVED 04 11th February 2009

1 3 FEB 2009

Dear Sirs,

RE: APPLICATION FOR BULKY GOODS ENTERPRISE, MIDDLE RIVER, INDUSTRIAL ESTATE, DOUGLAS

This letter is submitted in support of the enclosed planning application and we request that it be considered when determining the proposal. You will be aware of a previous refusal of permission in respect of unit 7 (ref: 08/01277/C) which is the subject of an appeal currently being held in abeyance while this proposal is considered. The current proposal which includes units 1, 2 and 7 has been submitted following discussions with your planning officers and takes account of their advice.

We believe that the main issue affecting the application arises from Business Policy 5 of the 2007 Isle of Man Strategic Plan which generally resists retailing on industrial estates. However, we note that the policy allows for storage and distribution uses and also permits retailing where it can be shown that the goods would not reasonably be sold from a town centre location because of their size or nature and would not detract from the vitality and viability of the town centre shopping area. This accords with UK policy in PPS6 which states that planning authorities should take account of any genuine difficulties in operating a business from a town centre. It is submitted that the proposal would not undermine the provisions of Business Policy 5 and we set out justification for this opinion as follows:

First, it is important to appreciate that the business involves bulky durable goods, mainly large electrical appliances such as televisions, fridge/freezers, washing machines and cookers. These typically weigh 60 to 100kg and because of their size, weight or shape require vehicular transport close by for customers to take them away, as they could not be carried home on foot or taken on a bus.

Second, the goods are graded, that is damaged in a variety of ways so each item is different from the next. It follows that each good must be viewed and purchased individually, unlike normal High Street stores where display models of a product type can be viewed and an identical product then ordered, with home delivery made from

Directors: Les Stephan Dip T.P, M.R.T.P.I Associate: Hazel Murphy Stuart Taylor BA (Hons), B.P.I., M.R.T.P.I, D.M.S

Planning & Development Finance & Administration Planning & Development

RTPI

Registered in England and Wales. Company No. 5610956

a central warehouse. This is a unique aspect of the business which is not found in normal High Street shops so there is no conflict in terms of direct competition.

Third, the site has to be serviced by bulk deliveries which are made twice a month by a 44 feet HGV trailer and the goods are unloaded by forklift truck. The operation usually takes about 4 hours and takes place outside normal business hours to avoid disruption to customers parking and other businesses. No objection to the previous application for unit 7 was raised by the Highway Authorities. We note the previous objection by the Manx Electricity Authority on traffic grounds but the problems they refer to are caused by others and their depot is remote from our clients site.

Fourth, it should be noted that the proposal is a mixed use which is dominated by storage and display areas. The display areas enable the individual goods to be viewed, but the retail sales desks occupy only a small part of those areas. The overall floor area totals $531 \mathrm{~m}^{2}$ of which $186 \mathrm{~m}(35 \%)$ would be purely storage using the mezzanine floors. On the ground floors about $286 \mathrm{~m}^{2}(54 \%)$ would be used to display and store goods and the remaining $59 \mathrm{~m}^{2}(11 \%)$ used for ancillary offices, loading area etc. You should note that goods would also be stored in parts of the display areas as they would remain in boxes until there was customer interest, so in effect the major part of the premises would be in storage use.

The staff all park away from the site. There are 6 allocated parking spaces for customers and sales figures show that on average only 5 to 6 customers call at the site per day, so the parking is adequate. The company advertises locally and the vast majority of customers are island residents and trade persons such as hoteliers and property developers. The latter often make multiple item purchases.

Fifth, it is appreciated the business involves a retail element but this is similar to other uses and we note that paragraph 9.2 .56 of the Strategic Plan recognises that some applications for retail related uses on industrial estates have been successful, including those enterprises where the items being sold cannot generally be sold from a town centre location. In the case of Middle River Estate a retail precedent has already been set by several companies close to our client's site. These include HSS Hire, City Electrical Factors, MFBP Building Supplies, West Coast Performance car garage, Autologic and CEF. These sell retail goods to the public and most of them have display and retail sales areas which are clearly advertised on the exterior of the premises. Indeed we understand that CEF have only very recently opened a lighting showroom at their premises. We conclude that our client's proposal is not dissimilar to others which have been approved in the area.

Finally, our client has examined premises in Douglas town centre to see if there are suitable premises there but has found no sites which are suitable in size, floor area, or availability of adjacent on-street or on-site customer parking which is essential for the type of use proposed.

In terms of the vitality and viability of the town centre the unusual nature of the goods sold mean that comparison shopping would not be affected and there is no significant pedestrian movement involved so vitality is not an issue. Also, there is a need for the type of goods sold as there are no similar uses in the town centre and the clientele are virtually all local.

In conclusion, we believe that the location proposed is the only one suitable to cater for the particular customer servicing and access requirements of the business. That requirement, together with the extent of floor area needed means a town centre location is not appropriate. The nature of the business which deals with a specific niche market for graded goods would not affect the viability of the town centre. We suggest that protection from change to other forms of retail use could be achieved by imposing conditions. In the UK paragraph 3.31 of Planning Policy Statement 6 confirms that conditions can be used to control the retail element and safeguard the town centre, including those to deal with the scale and format of development, parking and access, sub-division, ancillary elements, amount of floor space and limits on the range and mix of goods sold. We therefore consider that it would be appropriate to restrict the goods sold from the premises to graded bulky goods only to safeguard any possible conflict with the interest of the town centre.

If you any queries please do not hesitate to contact us. Examples of customer comments and photographs illustrating nearby retail sales and the sites' parking and servicing are enclosed.

Yours sincerely

David Wilks BSc (Hons) DipEM MRTPI MCMI FRSA