Officer Report

Application No.: 25/91100/B Applicant: Mr David Bellamy Proposal: Change of use from guesthouse to House in Multiple Occupation with 14 bedrooms, including the erection of secure bicycle and bin storage Site Address: Wavecrest 12 Empress Drive Douglas Isle Of Man IM2 4LQ Planning Officer: Paul Visigah Expected Decision Level: Planning Committee Recommended Decision: Permitted Date of Recommendation: 03.02.2026 _________________________________________________________________

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. Prior to the first occupation of any unit of accommodation within the development hereby approved, the refuse storage area shall be provided in full, in accordance with the approved plan (Drawing No. 110). The approved refuse storage shall be permanently retained thereafter for the sole purpose of waste storage.

Reason: To ensure adequate provision for waste management in the interests of residential amenity and service delivery.

• C 3. Prior to commencement of the development hereby approved details of the Secure covered bike store and Sheffield Bicycle stands shown on Drawing No. 100 received 18 December 2025, shall be submitted to and approved in writing by the Department. The secure cycle storage and Sheffield Bicycle Stands shall be installed prior to first occupation and permanently retained thereafter for the sole purpose of cycle parking.

Reason: To support sustainable transport objectives and ensure adequate provision for future occupants.

N 1. Note to Applicant: The applicant is advised to ensure that recycling receptacles/bins are kept at the property to allow for recycling of waste from the site.

This application has been recommended for approval for the following reason.

The proposal is considered to accord with General Policy 2, Strategic Policies 1 and 2 relating to sustainable development and the efficient re-use of an existing building, Spatial Policy 5 concerning development within established settlements, and Housing Policy 4 which supports appropriate residential provision in accessible urban locations. The scheme also complies with Environment Policies 34 and 35 in that it preserves the character of the Conservation Area within which the property sites, and with Transport Policies 1 and 4, and Strategic Policy 10, given the site's highly accessible position close to public transport, services and employment areas. The intensified residential use is compatible with the established character of the promenade, will not result in unacceptable impacts on neighbouring properties, and provides an appropriate level of amenity for future occupants. The proposal therefore represents an acceptable form of development.

Plans/Drawings/Information; This decision relates to the following plans and documents:

• o Cover Letter
• o Planning Statement
• o Area Schedule
• o Dwg. No. 001 Location and Site Plans
• o Dwg. No. 10 Existing Floor Plans
• o Dwg. No. 100 Proposed Ground and First Floor Plans
• o Dwg. No. 101 Proposed Second Third and Fourth Floor Plans; Received 17 December 2025; and
• o Drawing No. 110 Binstore Details received 2 February 2026.

_________________________________________________________________ Right to Appeal

It is recommended that the following organisation should not be given the Right to Appeal:

• o DOI Highways Division - No objection subject to conditions which have been applied.
• o Douglas City Council - No objection subject to conditions which have been applied. _________________________________________________________________

Officer’s Report

THE APPLICATION IS REFERRED TO THE PLANNING COMMITTEE AT THE REQUEST OF THE HEAD OF DEVELOPMENT MANAGEMENT

1.0 THE SITE - 1.1 The application property is Wavecrest, 12 Empress Drive, Douglas, which is an endterrace property located on the northern side of Empress Drive, as you approach from the southern section from The Douglas Promenade. The property comprises five stories and can be accessed through a staircase leading up from Empress Terrace. Most of the windows are timber sliding sash, although a few have been substituted with uPVC casements. The property has access to an outdoor patio area in front oof the property, but there are not parking provisions for the site.

2.0 THE PROPOSAL - 2.1 Planning approval is sought for Change of use from guesthouse to House in Multiple Occupation with 14 bedrooms, including the erection of secure bicycle and bin storage.

2.2 The proposal will provide for fourteen bedrooms. The internal configuration is as follows:

• a. Ground Floor: To provide two bedrooms with ensuite, an entrance hall, and a onebedroom apartment to serve as Managers Apartment.
• b. First floor: Offering two bedrooms with ensuite, a communal lounge (Rooms 1-7), and a Communal kitchen (Rooms 1-7).
• c. Second Floor: Four bedrooms with ensuite.
• d. Third Floor will have two bedrooms with ensuite, and a communal kitchen (Rooms 814), and communal lounge (Rooms 8-14).
• e. Fourth Floor: Four bedrooms with ensuite.

• 2.2.1 The applicants note that the manager's apartment is not included in any area requirements, as it is a separate unit and is provided with its own dedicated facilities.

2.3 The proposal would also include the following: a. Creation of a covered bike store and Sheffield Bicycle stands on the southwestern side of the property. The creation of an external bin store area built into the front boundary wall of the property by the highway. This will involve creating an area measuring 1.5m x 3.2m and 1.43m tall (internally). This will have a timber effect sliding external gates to allow access from the pedestrian walkway that abuts the property. This bin storage area will support two1100L bins.

- 3.0 PLANNING POLICY

3.1 Site Specific:

• 3.1.1 The site is within an area designated as Mixed Use on the Area Plan for the East (Map 4

• Douglas), and the site is within the Douglas Promenades Conservation Area. The site is not prone to flood risks.

3.2 TOWN AND COUNTRY PLANNING ACT 1999

• 3.2.1 S18 Designation of conservation areas

(4) Where any area is for the time being a conservation area, special attention shall be paid to the desirability of preserving or enhancing its character or appearance in the exercise, with respect to any buildings or other land in the area, of any powers under this Act.

3.3 Area: The Area Plan for the East Written statement:

• 3.3.1 Section 9.11 Development in areas of 'mixed use' "9.11.2Development types within areas of mixed use generally comprise a variety of different but compatible uses. Appropriate new uses may include a mix of shops and some services (financial and professional), food and drink, office and light industry, research and development, tourist and residential uses, and other uses such as clinics or health centres, childcare or education, community facilities, and places of assembly and leisure. Uses which are not compatible with residential development will generally not be supported within the areas of mixed use."

3.4 National: STRATEGIC PLAN

• 3.4.1 The following policies from the 2016 Strategic Plan are considered pertinent in the assessment of this application:

• 1. General Policy 2 - General Development Considerations.
• 2. Strategic Policy 1 - Efficient use of land and resources.
• 3. Strategic Policy 2 - Development focussed in existing towns and villages.
• 4. Strategic Policy 4 - Seeks to Protect or enhance the fabric and setting of Conservation Areas (etc.).
• 5. Strategic Policy 10 - development should promote integrated journeys, minimise car use and facilitate other modes of travel.
• 6. Strategic Policy 11 - Housing needs.

• 7. Environment Policy 34 - Preference for the use of traditional materials in the maintenance, alteration or extension of pre-1920 buildings.
• 8. Environment Policy 35 - Seeks to preserve or enhance the character or appearance of Conservation Areas.
• 9. Environment Policy 42 - Designed to respect the character and identity of the locality.
• 10. Housing Policy 1 - Housing needs.
• 11. Housing Policy 4 - New Housing to defined existing towns.
• 12. Transport Policy 1 - Proximity to existing public transportation services.
• 13. Transport Policy 4 - Highway Safety
• 14. Transport Policy 7 - Parking Provisions.
• 15. Paragraph 8.1.1 states: "The principal objective of the Government's housing policy is to ensure that sufficient housing, to appropriate standards, is made available to meet demands created by the growth in population and changing household sizes."
• 16. Paragraph 8.1.5 - The Department has determined that it is necessary to plan for 5100 additional dwellings over the Plan period 2011 to 2026.
• 17. Community Policies 7, 10 and 11 provide guidance in respect of minimising criminal activity and reducing spread of fire, while Infrastructure Policy 5 deals with methods for water conservation.

• 3.4.2 While no policy specifically mentions the conversion of buildings into HMO's, there are several policies regarding the conversion of buildings to flats, and it is considered that the principles in these policies, especially on safeguarding living amenities, should be applied to this application.

• a. Paragraph 8.13.1 states: "There are in the Island, and particularly in Douglas, many substantial buildings which, because of their size or form, are no longer suitable for the originally 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."
• b. Housing Policy 17 states: "The conversion of buildings into flats will generally be permitted in residential areas provided that:

• (a) adequate space can be provided for clothes-drying, refuse storage, general amenity, and, if practical, car-parking;
• (b) the flats created will have a pleasant clear outlook, particularly from the principal rooms and
• (c) if possible, this involves the creation of parking on-site or as part of an overall traffic management strategy for the area."

- 4.0 OTHER MATERIAL CONSIDERATIONS

4.1 Residential Design Guide (2021)

• 4.1.1 This document provides advice in Section 7 deals with impact of developments on neighbours. Paragraph 7.2.2 defines the various tiers of rooms and windows on a dwelling, and this includes the following:

• o Primary Habitable Rooms: Living Rooms, Dining Rooms, Kitchens which includes dining facilities and Conservatory;
• o Secondary Habitable Rooms: Bedrooms and kitchens; and
• o Non-Habitable Rooms: these include bathrooms, utility rooms, hallways/corridors, stairs/landings, garages, porches, and storage.

• 4.1.2 Section 3.1 deals with Local distinctiveness. Section 3.1 of the Residential Design Guide (2021) highlights that new development should respond to the character and context of its surroundings, which are shaped by locally distinctive patterns of development, landscape, culture, and biodiversity. Proposals should respect established building lines, heights, and orientation, maintain a positive relationship with

neighbouring properties and movement patterns, and, where possible, retain mature landscaping features that contribute to the area's identity. Where context has been weakened by previous development, opportunities should be taken to enhance quality and reinforce a strong sense of place.

4.2 Planning Policy Statements: 1/01 POLICY AND GUIDANCE NOTES FOR THE CONSERVATION OF THE HISTORIC ENVIRONMENT OF THE ISLE OF MAN

• 4.2.1 POLICY CA/2 - Special Planning Considerations
• 5.0 PLANNING HISTORY

5.1 The application site has been the subject of the following panning applications:

• 1. PA 86/01378/B for Alterations to install external fire escape and emergency exit, Wavecrest, 12 Empress Drive, Douglas. This was approved by the Planning Committee on 16.01.1987.
• 2. PA 87/01385/C for Change of use from guest house to office accommodation, Wavecrest, 12 Empress Drive, Douglas. This was refused by the Planning Committee on 11.09.1987.

6.0 REPRESENTATION Copies of representations received can be viewed on the Government's website. This report contains summaries only.

6.1 Douglas City Council has made the following comments on the application (19.12. 2025): Although the Council is not raising an objection against the proposed change of use, we would kindly ask that the applicant considers the installation of compartmental recycling bins within the communal kitchen areas. There is a communal recycling area close to the development site and the installation of this type of bin would encourage recycling and reduce the amount of residual waste.

6.2 DOI Highways Services have stated that the proposal would have no significant negative impact upon the highway network in terms of highway safety, highway operation and car parking, and that they not oppose (DNO) the application as the site is in a sustainable location in Douglas centre and is reusing an existing building, subject to conditions on bin store and secure cycle storage being conditioned on permission (22 December 2025). - 6.3 The following consultees have not provided any comments, although they were consulted on 18 December 2025:

• o DEFA Environmental Health Team
• o Manx National Heritage
• o DEFA Registered Buildings Officer

6.4 No comments have been received from neighbouring properties.

- 7.0 ASSESSMENT

7.1 The fundamental issues to consider in the assessment of the current application are:

• 1. The principle of the proposed change of use;
• 2. Impacts on the Conservation Area;
• 3. Potential Parking Impacts;
• 4. potential amenities for future occupants.

7.2 Statutory Test - Section 18 (4)

• 7.2.1 In accordance with Section 18(4) of the Act, it is considered that the proposal does not conflict with the objectives set out therein. The application has therefore been assessed in the

• context of the relevant policies identified below and within Section 3, as well as the guidance documents detailed in section 4 of this report.
• 7.2.2 It should be noted that there are no external changes the appearance of the building, which is the key feature of the site that contributes to the character of the Conservation Area, with the minor site changes such as the creation of the new waste storage area not considered sufficient to significantly alter the character of the area. Therefore, it is considered that the proposal would preserve the character of the Conservation Area and passes the test.
• 7.3 Principle of the proposal (GP2, STP 1 & 2, and HP 4)

• 7.3.1 As noted in 3.1, the site is in an area of Douglas zoned as mixed use, with the use of the building for residential purposes in the form of an HMO, which is in keeping with the dominant use of mixed-use areas noted in Paragraph 9.11.2 of the Area Plan considered to weigh in favour of the proposed use. It should be noted that the use as an HMO is more in keeping with the Area Plan than the existing use as a guest house. Further to the factors highlighted above, the change of use of former Guest houses is becoming increasingly common as an alternative use for former guesthouses, along with the conversion to flats in Douglas.
• 7.3.2 In addition, the Island is experiencing an ongoing reduction in household sizes, meaning more people are looking for smaller sized accommodation, and there are also seasonal/temporary/migrant workers looking for reasonable temporary accommodation. Moreover, the property has been vacant for some time, meaning the proposed change would be a meaningful conversion. This proposal would offer a suitable alternative to flats, with the provision of HMO serving as a sustainable supplement to the existing housing supply.
• 7.3.3 Therefore, it is considered that the principle of the proposed development is acceptable on balance at this location. This conclusion is reached without prejudice to the subsequent assessment of the other key matters detailed in section 7.1 of this report and would be addressed in the following sections.

7.3 Impact on Character and Appearance (EP 34 & 35, STP 4 & 5, GP 2, PPS 1/01, PC 1/98)

• 7.3.1 In assessing the potential impacts of the proposal on the character and appearance of the property and the wider Conservation Area, the key consideration is whether the works respect the established architectural form, materials, and detailing that contribute to the area's significance. As there would be no external changes proposed to the building's facade, with the Victorian façade retained, there would be no adverse impacts on the Conservation Area.
• 7.3.2 With regard to the proposed works to alter the site frontage to create a new 3.7m wide bin storage area with a sliding gate facing the street, it is considered that this is a significant improvement compared to existing situation where bins are set out in the open for collection, rather than within an enclosure, or set out in the open as it is with some properties within the immediate street scene, and this is considered to preserve the character of the area.

• 7.3.2 The proposed covered bike store and Sheffield Bicycle stand on the southwestern side of the building would not be on the prominent part of the site, and offer a more discreet placement, which would ensure impact on the character of the site. Besides, their design is utilitarian, and it is not uncommon to have these features in buildings and sites within the Conservation Area. Moreover, when these features viewed from the adjoining highway, they would read as subordinate elements on site, preserving the overall composition and avoiding visual clutter.
• 7.3.3 Taken together, the works demonstrate a context-sensitive approach, respecting the site and surroundings in terms of siting, scale, and materials. The proposal would preserve and modestly enhance the character and appearance of the existing building on site and the Conservation Area, meeting the requirements of Strategic Policies 4 and 5, Environment Policy 35, and General Policy 2(b, c and g) of the Strategic Plan.

7.4 The potential impact on parking provision (TP1, TP4, GP2, STP 10)

• 7.4.1 In terms of possible impacts on parking and highway safety, it is noted that there would be no parking provided on the site, as is currently the case, and as is the case for most similar properties in this part of Douglas, where on-street parking is dominant. However, it is considered that the proposed occupancy rate would not be so different from the previous use of the property as a guest house. Whilst it is considered that the occupancy will be at a steadier level, compared to the fluctuations in tourist use, it is also noted that some occupant would be seasonal occupants as with many HMO's. Thus, it is not considered that demand for parking would be considerably at variance with the approved use of the property.
• 7.4.2 Moreover, the proposal would be reusing a redundant building, which is of historic interest (being in a Conservation Area), is within walking distance to town centre, positioned within a 2-minute walk from the bus route along the promenade and about 10 minutes to the nearest taxi rank, and is within walking distance from public amenities and employment areas within Douglas; conditions that align with the exemptions allowed under Paragraph A.7.1 of the Strategic Plan. When these are combined with the ample cycle provision that is part of the proposed development, it is not considered that the impacts resulting from the lack of on-site parking would be significant.
• 7.4.3 Added to the factors highlighted above, the advice offered by DOI Highways who are the professionals tasked with providing professional advice on parking and highway safety concerns confirm that the scheme is acceptable, on the basis that site is in a sustainable location in Douglas centre and is reusing an existing building, subject to conditions on bin store and secure cycle storage being conditioned on permission, and these add further weight in favour of the scheme. Hence, it is not considered that the absence of on-site parking in this case would be so adverse as to result in refusal of the scheme for the reasons that have been highlighted above.

7.5 Amenity for Future Occupants (GP2 & RDG 2021)

• 7.5.1 With regard to the level of amenity that will be afforded future occupants of the property, it is considered that the site provides only a small patio to the front and no substantial private outdoor space; however, this is typical for properties in this part of Douglas. Future occupants will benefit from immediate access to high quality public amenity areas, including Villa Marina Gardens, the Promenade, and the beach, as well as nearby shops and restaurants in the immediate vicinity. These facilities collectively ensure an adequate level of external amenity.
• 7.5.2 The development now incorporates Sheffield bicycle stands and a covered, secure cycle storage facility. This provision aligns with the Isle of Man Government's Active Travel Strategy and supports sustainable transport choices by offering safe, weather protected storage for residents.
• 7.5.3 A new bin storage area has been created at the site frontage, providing convenient and accessible waste management arrangements. Douglas Borough Council has raised no objection to existing waste storage provision, noting that the installation of compartmental recycling bins within the kitchen areas would help encourage recycling and reduce residual waste. The arrangements are considered acceptable when assessed against the contents of their consultation response.
• 7.5.4 Internally, the property benefits from two communal lounges, which provide generous shared living space for residents and retain much of the former guesthouse's character. These areas offer a strong level of internal amenity and contribute positively to the overall living environment within the HMO.

• 7.5.5 Most bedrooms are well-proportioned and benefit from good outlook through large windows. Two bedrooms, along with the communal lounges, face the rear landscape where the raised landform limits long distance views. However, the outlooks are towards vegetated woodland rather than built form, ensuring that the spaces do not feel enclosed or oppressive. Natural lighting levels also remain adequate.
• 7.5.6 Taking the internal communal spaces, bedroom standards, and wider context into consideration, the development is considered to provide an appropriate level of amenity for future occupants. Although the site offers only a small patio area and no substantial private outdoor space, this is typical of the area, and residents will have immediate access to highquality public amenity areas in the immediate vicinity. When viewed as a whole, the proposal delivers a satisfactory level of amenity of both internal and external amenity.

- 8.0 CONCLUSION

8.1 The proposal represents an efficient reuse of a redundant building in close proximity to the town centre, contributing positively to the local housing supply. The intensified residential use is consistent with other established uses along the promenade, and it is not expected to give rise to unacceptable impacts on neighbouring properties. Although no on-site parking is provided, the site benefits from excellent accessibility to public transport, taxi ranks, services, and employment areas within the town centre, thereby reducing reliance on private car use. The impact on the character of the site and the surrounding Conservation Area is considered acceptable. - 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;
• 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.

I confirm that this decision has been made by the Planning Committee in accordance with the authority afforded to that body by the appropriate DEFA Delegation and that in making this decision the Committee has agreed the recommendation in relation to who should be afforded interested person status and/or rights to appeal.

Decision Made: Permitted Date: 16.02.2026 Signed : Mr Pieran Shen Presenting Officer

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