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PROPOSED RETAIL DEVELOPMENT, SPRING VALLEY TRADING ESTATE, DOUGLAS, ISLE OF MAN
ISLE OF MAN DEVELOPMENT COMPANY LIMITED DECEMBER 2025
Prepared by: Richard Shepherd Reviewed by: Richard Shepherd Telephone: 07549 209462
Email: [email protected]
Report Issue Date: December 2025
This document has been prepared and checked in accordance with the Lambert Smith Hampton Quality Assurance procedures and authorised for release.
Signed:
For and on behalf of Lambert Smith Hampton
1.0 INTRODUCTION ... 3 2.0 CONSIDERATION OF ADDITIONAL SEQUENTIAL ALTERNATIVE SITES ... 5 3.0 SUMMARY AND CONCLUSIONS ... 9
1.1 The Isle of Man Development Company Ltd submitted a planning application (reference 25/90902/B) in October 2025 which provides for a retail warehouse foodstore development at Spring Valley Trading Estate on the Isle of Man.
1.2 The description of development for the proposal is as follows:
'Proposed retail warehouse foodstore together with access, car parking, servicing, landscaping and associated works.'
1.3 The proposed foodstore would accommodate:
1.4 The application site comprises 0.51 hectares and is situated in the western part of Douglas and to the west of the town centre. The site forms part of Spring Valley Trading Estate, which is an established location for industrial, warehousing, trade counter, and retail uses. The site is bounded by: a vacant site to the north (beyond which lies a Screwfix retail trade counter use); residential dwellings to the east; a Pets at Home retail unit to the south; and, the estate access road to the west.
1.5 The planning application documents included a Planning and Retail Statement (authored by Lambert Smith Hampton and dated September 2025) which set out the compliance of the proposal with relevant planning policy requirements.
1.6 This included the sequential approach to development, with the potential offered by six different sites in and around Douglas town centre assessed in respect of their availability and suitability to support a comparable form of development.
1.7 The Isle of Man Government has reviewed the submitted sequential assessment and has requested that consideration be given to the potential offered by a number of additional sites.
1.8 We consider the merits of each of these sites in the following Section 2 of this Supplementary Sequential Assessment. This Assessment should be read in conjunction with the Planning and Retail Statement and, in particular, paragraphs 4.13 to 4.19 of the Statement which set out a series of parameters of relevance when determining the potential suitability of sites.
1.9 Key parameters in respect of this application proposal comprise the need for:
2.1 We consider the additional sites identified by the Isle of Man Government below. Where a site is neither available nor suitable (with reference to the parameters identified in the previous Section 1) then it can be discounted from further consideration. Furthermore, as we go on to establish below, some of the additional sites identified offer no material sequential benefit in respect of their connectivity to Douglas town centre. We understand that all of the sites are derived from the Government's Unoccupied Urban Sites: East (November 2020) schedule/plan and they are referenced on this basis.
Former James Caine Furniture/Westmoreland Development Site, Demesne Road (Unoccupied Urban Sites Reference UUS1)
2.2 Redevelopment of the Westmoreland Development Site is being progressed by the Manx Development Corporation pursuant to planning permission 23/00291/B, which was approved in May 2025.
2.3 The site (as identified by the Unoccupied Urban Sites: East schedule) comprises approximately 0.9 hectares. It is considered to be an out of centre site for retail planning policy purposes, being approximately 500 metres from the Strand Street Mixed Use Proposals Area (as defined by the Area Plan for the East Proposals Map), which acts as Douglas' de facto primary shopping area.¹
2.4 The description of development for this approved scheme is as follows:
'The development proposes the construction of 133 new dwellings split across apartments, townhouses, small blocks of flats and a senior living block. In addition, a new scout hut/community pavilion, refurbishment and extension of Crookall House as office space, replacement existing sub-station and associated external landscaping, highways and drainage works.'
2.5 The proposal provides for a mixed-use development which is based on the '20-minute neighbourhood' concept. The type of mixed-use development proposed does not and could not accommodate a foodstore capable of supporting main food shopping trips.
2.6 The Westmoreland Development Site is not available to accommodate the proposed use and a more suitable form of development is being pursued. The site can therefore be dismissed as a sequential alternative.
Land Bound by South Quay and Fort Anne Road (Unoccupied Urban Sites References UUS2 and UUS3)
2.7 The above site comprises two adjoining adjacent plots as identified by the Unoccupied Urban Sites: East schedule.
2.8 LSH estimates that the two sites in combination comprise approximately 0.8 hectares. It is considered to be an out of centre site for retail planning policy purposes, being approximately 600 metres from the Strand Street Mixed Use Proposals Area.
2.9 The combined site is irregularly-shaped and is narrow in its central part. The shape of the site is not well suited to accommodating large format retailing, which generally requires a rectangular area for the store and an adjacent additional area to support the car parking element of the proposal.
2.10 More problematically, the topography of the site would not support large format retailing given that the site effectively forms the 'cliff face' between Fort Anne Road to the south leading down to South Quay to the north. Given the changes in levels across the site there is no prospect whatsoever of accommodating a similar form of development to that proposed at the application site.
2.11 The adopted Area Plan for the East Proposals Map (Douglas Inset Map) identifies that the southern part of the site forms Allocations DH004g 'South Quay' and DH019g 'South Quay'. These allocations form part of the Isle of Man's identified housing land supply
¹ Both this measurement and all others specified in this report in respect of sites' sequential status relate to the most direct walking route between the edge of the subject site and the edge of the Strand Street Mixed Use Proposals Area as defined by the Area Plan for the East Proposals Map.
2.12 Given the nature of the site, it is considered that residential development remains a preferable form of development. Land Bound by South Quay and Fort Anne Road can be straightforwardly dismissed as a large format retail site on the ground of suitability.
Former Fairfield School Site, Bounded by Tynwald Street and Peveril Street (Unoccupied Urban Sites Reference UUS6)
2.13 Unoccupied Urban Sites Reference UUS6 is bounded by: Clarke Street to the north; the curtilage of residential dwellings to the east; Tynwald Street to the south; and, Peveril Street to the west.
2.14 LSH estimates that the site comprises less than 0.3 hectares. It is considered to be an out of centre site for retail planning policy purposes, being approximately 500 metres from the Strand Street Mixed Use Proposals Area.
2.15 As established by the submitted Planning and Retail Statement, any alternative site would need to comprise 0.4 hectares (as an absolute minimum) in order to offer any theoretical potential to support a broadly similar form of food retail development.
2.16 Site reference UUS6 is notably smaller than this. Furthermore, it is situated within an area characterised by its tight urban grain which is largely residential in character. There is no realistic prospect of assembling a larger site, and the opportunity can therefore be dismissed on the ground of suitability.
Area of Land Bounded by Poplar Terrace, Victoria Avenue and Victoria Road in Little Switzerland (Unoccupied Urban Sites Reference UUS14)
2.17 Unoccupied Urban Sites Reference UUS14 is split into two parts by Victoria Avenue. The larger plot is bounded by: Poplar Terrace to the north west; Victoria Avenue to the north east; Victoria Road to the south east; and, a children's nursery and residential dwellings to the south west.
2.18 LSH estimates that this part of Unoccupied Urban Sites Reference UUS14 site comprises just under 0.9 hectares. The edge of the site is approximately 1.5 kilometres from the edge of the Strand Street Mixed Use Proposals Area. It is therefore out of centre in respect of its sequential status.
2.19 We understand that the site operates as the Duke TT Village over the two weeks of the Isle of Man TT. Previously, the site accommodated Victoria Road Prison which was decommissioned in 2008. Demolition work subsequently commenced in late 2012 and was completed in 2013.
2.20 The adopted Area Plan for the East Proposals Map (Douglas Inset Map) identifies that the site forms part of Allocation DH046g 'Vacant Site (former Victoria Road Prison) and Edale (including Eastcliffe)'.
2.21 Paragraph 12.17.4 of the Area Plan for the East identifies that the site is allocated for predominantly residential use.
2.22 The Development Brief for the site provided within the Area Plan for the East states that:
'The use of the site shall be limited to the creation of a residential development (which may also feature residential car and/or day care uses and/or sheltered housing) and/or any uses associated with civic or cultural uses.'
2.23 The site is located within the Little Switzerland suburb and is surrounded by a number of residential dwellings. The allocation is consistent with surrounding land use and would appear to remain a suitable use for the site.
2.24 Notwithstanding the above, it is important to reiterate that the site is out of centre in retail planning policy terms and is relatively distant from Douglas's de facto primary shopping area.
2.25 Whilst it is recognised that the Government considers that a sequential approach to retail development applies in the Isle of Man, the test is not articulated in any detail within the adopted plan.
2.26 Isle of Man Strategic Plan Business Policy 5 seeks to generally direct retailing towards town centre locations.
2.27 Appendix 2 of the Area Plan for the East confirms some general principles that are to be applied in considering additional retail development. These include the need to adopt a sequential approach to development, with the preferred location being existing town centres followed then by edge of centre locations.
2.28 Appendix 2 goes on to identify that, where practicable and justified in retailing terms, all new large or medium convenience store developments should be located within or on the edge of centre. Furthermore, it recognises the availability of convenient and easily accessible car parking will be essential.
2.29 In practice, the plan does not seek to differentiate in respect of the respective merits of different out of centre sites. There is nothing within the plan to suggest that one out of centre site could be favoured over another in sequential terms.
2.30 Notwithstanding this, we reiterate that Unoccupied Urban Sites Reference UUS14 is not only out of centre, but also relatively distant from Douglas town centre.
2.31 Urban Sites Reference UU cannot be considered to be well connected to Douglas' primary shopping area such that it would support any tangible level of linked trips on foot with the town centre should a foodstore be developed on the site. In practice, it is highly unlikely that linked trips (potentially with heavy bags of grocery shopping) would be undertaken on foot between sites in the Little Switzerland area and the Strand Street Mixed Use Proposals Area.
2.32 Whilst the site could likely support some vehicular linked journeys to the town centre, this is also true of the Spring Valley Trading Estate application site as both are a matter of minutes from the centre by car. If shoppers have a need to visit the town centre, there would be no difference between the two sites in respect of their propensity to support a linked trip by car.
2.33 Given all of the above, we find that Unoccupied Urban Sites Reference UUS14 is better suited to residential development and that, in any event, it offers no material advantage in sequential terms relative to the application site.
Former Shoprite Head Office, Victoria Road (Unoccupied Urban Sites Reference UUS14)
2.34 The second, smaller plot associated with Unoccupied Urban Sites Reference UUS14 is bounded by: the curtilage of residential properties to the north west; Linden Grove to the north east; Victoria Road to the south east; and, Victoria Avenue to the south west.
2.35 LSH estimates that the site comprises approximately 0.5 hectares. The edge of the site is approximately 1.6 kilometres from the edge of the Strand Street Mixed Use Proposals Area. It is therefore out of centre in respect of its sequential status.
2.36 The same planning policy position (as outlined above in respect of the larger part of Unoccupied Urban Sites Reference UUS14) applies to this element of Unoccupied Urban Sites Reference UUS14.
2.37 As such, it is established that:
2.38 Given all of the above, our two key conclusions in respect of this site are identical to those provided in respect of the larger element of Unoccupied Urban Sites Reference UUS14.
2.39 Firstly, in accordance with the provisions of the development plan, the site is better suited to residential development.
2.40 Secondly, the site can be considered a distant out of centre site and therefore offers no benefit in sequential terms relative to the application site.
Surface Level Car Parks at Lord Street (Unoccupied Urban Sites Reference UUS18, UUS19 and UUS20)
2.41 In respect of the definition of the above three sites:
2.42 All three sites are currently used as surface car parking.
2.43 All three of these sites are located close to the intersection of Lord Street and Parade Street, close to the harbour. The three sites are located just to the south east of Strand Street Mixed Use Proposals Area and are edge of centre sites in sequential terms.
2.44 Each of the three sites is allocated by the adopted Area Plan for the East Proposals Map (Douglas Inset Map) for residential purposes (the three sites respectively comprise Allocations DM004g, DM007g, and DM008g). The expectation is therefore that the redevelopment of all of the sites will accommodate a residential element.
2.45 In addition, we note that the potential of all three of the above sites was considered by Central Douglas Masterplan, which was undertaken by a consultancy team led by IBI TaylorYoung and which reported in July 2014. Whilst the Masterplan is rather dated, it formed part of the evidence base for the adopted Area Plan for the East and its proposals have generally been 'carried through' to the adopted plan.
2.46 The Masterplan sets out a series of area-based proposals to help improve six key areas. The three sites comprise 'The Fort' opportunity area.
2.47 In summary, the Masterplan identifies that:
2.48 We are unaware of any planning application proposals being progressed in respect of Unoccupied Urban Sites References UUS18 and UUS19.
2.49 The eastern part of Unoccupied Urban Sites References UUS20 is the subject of planning application reference 23/01039/B, which seeks to provide for the redevelopment of the site for a casino, offices and 25 residential apartments. The application was registered in October 2023 and, at the time of reporting, remains undetermined.
2.50 In considering all three of these sites, it is important to note that:
2.51 All three sites provide an opportunity for appropriately-scaled development which makes a positive contribution to a sensitive waterside setting, creates homes, and support wider uses which contribute to Douglas' visitor offer.
2.52 Given the planning policy position, it is clear that these sites are not well suited to accommodate a foodstore use.
Office Development Site, South East of Victoria Road (Unoccupied Urban Sites Reference UUS22)
2.53 Unoccupied Urban Sites Reference UUS22 is located adjacent to Site Reference UUS14.
2.54 It is bounded by: Victoria Road to the north west; Victoria Avenue to the north east; a wooded area to the south east; and, Palace Road to the south west.
2.55 LSH estimates that Unoccupied Urban Sites Reference UUS22 comprises approximately 2.1 hectares. The edge of the site is approximately 1.4 kilometres from the edge of the Strand Street Mixed Use Proposals Area. It is therefore out of centre in respect of its sequential status.
2.56 The adopted Area Plan for the East Proposals Map (Douglas Inset Map) identifies that the site comprises Allocation DM013g 'Little Switzerland'.
2.57 The area surrounding the site is site is primarily residential in character. The allocation provide for residential redevelopment and is therefore consistent with surrounding land use.
2.58 Notwithstanding its allocation, this site effectively forms a cluster with Unoccupied Urban Sites Reference UUS14 and 22. The three sites are located between 1.4 kilometres and 1.6 kilometres from the edge of the Strand Street Mixed Use Proposals Area as defined by the Area Plan for the East Proposals Map.
2.59 None of these sites are considered to be particularly well connected to the Douglas' de facto primary shopping area and none would support any material level of linked trips to the town centre on foot.
2.60 For this reason, we do not consider Urban Sites Reference UUS22 to be sequentially preferable to the application site
Former Park Road School Site, South East of Victoria Road (Unoccupied Urban Sites Reference UUS13)
2.61 It is recognised that the Park Road School could be 'squared off' through inclusion of the Bowling Green Inn which lies to the south east. This would create a site of circa 0.9 hectares.
2.62 The Bowling Green Inn closed in December 2022 and was previously being marketed for lease by Chapman Chartered Surveyors. However, at the time of reporting the listing has been withdrawn from their website.
2.63 As such, it appears that the Bowling Green Inn is not currently available.
2.64 Notwithstanding the above, the previously submitted Planning and Retail Statement identified that the Department of Education, Sport and Culture intends to retain the wider site for education use as no other potential site in the Douglas area has been deemed suitable for a school.
2.65 Paragraphs 4.42 to 4.43 of the submitted Planning Statement identified that:
'...whilst the site is physically large enough to accommodate a foodstore use, it is embedded within a residential area with relatively narrow highways which are subject to on-street parking. The site is not well suited to support a foodstore operation.
The former Park Road School can also be discounted from the sequential assessment on the grounds of availability and suitability.'
2.66 The above conclusion continues to apply irrespective of whether or not the Bowling Green Inn is included as part of the site.
3.1 Planning application reference 25/90902/B provides for a retail warehouse foodstore development at Spring Valley Trading Estate on the Isle of Man.
3.2 In considering the application proposal, the Isle of Man Government has requested that consideration be given to the merits of a number of additional sequential alternative sites in respect of their potential to accommodate a broadly similar foodstore development.
3.3 This Supplementary Sequential Assessment has reviewed each of the eight sites identified. In order for it be argued that any of these sites offer an advantage relative to the application site, the alternative would have to offer a material benefit in respect of its connectivity to Douglas town centre and be both available and suitable to accommodate the proposal.
3.4 Section 2 of this Assessment has reviewed each of the sites in this context. We believe it to be clear that none of the identified sites offers genuine potential to support the subject proposal in a sequentially superior location.
3.5 Isle of Man Strategic Plan Business Policy 5 identifies that, on land zoned for industrial development, retailing will only be permitted where the items sold could not reasonably be traded from a town centre location.
3.6 Appendix 2 of the Area Plan for the East briefly summarises the recommendations of the Isle of Man Island Retailing Study, Update 2009. Whilst the detail of this Study is now clearly out of date, Appendix 2 confirms some general principles that are to be applied in considering additional retail development. These include inter alia:
3.7 This Assessment has demonstrated that there is no sequentially preferable location to accommodate the proposed development. As such, it is demonstrated that the proposal accords with the provisions of the above development plan policies in respect of the sequential approach to development.
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