**Document:** APL Statement
**Application:** 23/01291/B — Replace the roof finish
**Decision:** Permitted
**Decision Date:** 2024-03-15
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/56869-braddan-wool-control-replacement-roof/documents/1109390

---

# APL Statement

## Planning Statement In Support Of The Replacement Of The Existing Roof, The Old Wool Exchange, Peel Road, Douglas Im1 4Lx

![A photograph showing a long, single-story stone building with a weathered corrugated roof situated alongside a road with parked cars and a traffic light.](https://images.planningportal.im/2023/12/6892905.png)

- 1.0 Introduction
- 1.1 The Old Wool Exchange is an existing building situated on the south western side of Peel Road, sitting between the Brown Bobby fuel filling station and a new development of apartments to the south east.
- 1.2 The existing building is a stone structure with a sheeted roof which was formerly used for the storage and control of wool, administered by Government. Prior to that the building was used as a drill hall, having been built in 1896.
- 1.3 In 2013 the building was sold and used for the storage of various goods with two days a week the goods being available for sale. In 2018 the use of the building changed to the sale and maintenance of flues, fires and fuel burners, operated by the current applicant, Village Fireplaces and Stoves Ltd. The building is used as a showroom with the actual goods stored and supplied from another unit in Hills Meadow. The present owners have spent a lot of time and money on repairing, refurbishing and improving the building with all works to the exterior faithfully replicating the original finishes as far as has been practicable.
- 1.4 The existing roofing comprises cement sheeting which also includes chrysotile (white asbestos) (see attached certificate of analysis). The roof is nearing its useful life and requires to be replaced, noting the appropriate safeguards for dealing with the existing roofing materials (please refer to the letter from BB Consulting Engineers).
- 1.5 The building is old and interesting, due not only to its construction and position within Douglas but also due to its history of usage and its age. It has previously been considered for Registration although at the present time remains unprotected in planning terms either through Conservation or Registered Building status.

- 2.0 The proposal
- 2.1 Proposed is the removal of the existing roof sheeting and its replacement with Steadmans Composite roof sheeting, details of which are provided. This material is not dissimilar to what exists, albeit newer and clean, and also incorporates insulation which will assist with the maintenance of the building itself and a more comfortable occupation by those using it.
- 2.2 The new sheeting will be Merlin Grey.

- 3.0 Planning context
- 3.1 The site lies within an area designated on the Area Plan for the East, adopted in 2020, as Mixed Use - St. George’s - and also part of a Comprehensive Treatment Area - Riverside and Peel Road.
- 3.2 The Mixed Use Area is referred to in the Written Statement as follows:

Mixed Use Area 4 – St George’s This is the business district of Douglas and is characterised by offices, many serving financial institutions. Athol Street is notably the core of this area and is representative of the economic well-being of the Island. There is a smattering of food and drink uses supporting the area. The primary office frontage along Athol Street is notated by the hatched line on Map 5.

Town Centre – Mixed Use Proposal 4 There will be a presumption in favour of offices and financial and professional services along Athol Street. Within the area, but outside of Athol Street, offices, financial and professional services, food and drink and some residential uses will also be acceptable. Uses which conflict with these will generally not be supported. As this area lies partly within a Conservation Area, development plans should pay regard to the Conservation Area Character Appraisal for Athol Street and Victoria Street.

- 3.3 The CTAs “represent sites which have opportunities for economic, environmental, infrastructure or social improvement but which would benefit from some level of co-ordinated enhancement/change” and “a lever to encourage and enable redevelopment and positive change.”
- 3.4 A specific brief is provided:

CTA Proposal 3 - Riverside and Peel Road (Treatment Plan) Development of this area could include leisure, retail warehouse (bulky goods) and residential uses. The acceptability of the range of uses and their precise location shall be assessed as part of a development brief taking into account accessibility, highway impact, design, visual impact and flood mitigation. The presence of buried river channels and 19th century water management channels such as mill leats may require

## carefully engineered groundworks. Provision for a cycle route that links to existing and future cycle networks including the Heritage Trail shall be included.

- 3.5 The site is not shown as being at risk of flooding on the national flood risk maps, is not within a Conservation Area and the building is not Registered. A small part of the Registered Tree Area (RA1999) is included in the site on the south west boundary.
- 3.6 The Strategic Plan provides non geographic policy advice on development within the Island. The following policies are considered relevant in this case:

Strategic Aim: To plan for the efficient and effective provision of services and infrastructure and to direct and control development and the use of land to meet the community’s needs, having particular regard to the principles of sustainability whilst at the same time preserving, protecting, and improving the quality of the environment, having particular regard to our uniquely Manx natural, wildlife, cultural and built heritage.

- Strategic Policy 3: Proposals for development must ensure that the individual character of our towns and villages is protected or enhanced by:

- (a) avoiding coalescence and maintaining adequate physical separation between settlements; and
- (b) having regard in the design of new development to the use of local materials and character.

- Strategic Policy 4: Proposals for development must:

- (a) Protect or enhance the fabric and setting of Ancient Monuments, Registered Buildings(1), Conservation Areas(2) , buildings and structures within National Heritage Areas and sites of archaeological interest;
- (b) protect or enhance the landscape quality and nature conservation value of urban as well as rural areas but especially in respect to development adjacent to Areas of Special Scientific Interest and other designations; and
- (c) not cause or lead to unacceptable environmental pollution or disturbance.

- Strategic Policy 5: New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases the Department will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies.

General Policy 2: Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development:

- (a) is in accordance with the design brief in the Area Plan where there is such a brief;
- (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them;
- (c) does not affect adversely the character of the surrounding landscape or townscape;
- (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses;
- (e) does not affect adversely public views of the sea;
- (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks;
- (g) does not affect adversely the amenity of local residents or the character of the locality;
- (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space;
- (i) does not have an unacceptable effect on road safety or traffic flows on the local highways;
- (j) can be provided with all necessary services;
- (k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan;
- (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding;
- (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and
- (n) is designed having due regard to best practice in reducing energy consumption.

Environment Policy 34: In the maintenance, alteration or extension of pre-1920 buildings, the use of traditional materials will be preferred.

- Environment Policy 42: New development in existing settlements must be designed to take account of the particular character and identity, in terms of buildings and landscape features of the immediate locality. Inappropriate backland development, and the removal of open or green spaces which contribute to the visual amenity and sense of place of a particular area will not be permitted. Those open or green spaces which are to be preserved will be identified in Area Plans.

- Environment Policy 43: The Department will generally support proposals which seek to regenerate run-down urban and rural areas. Such proposals will normally be set in the context of regeneration strategies identified in the associated Area Plans. The Department will encourage the re-use of sound built fabric, rather than its demolition.

- 3.7 The site and development is considered to accord with all of the policies which support sustainably located development (Strategic Policies 1, 2 and 10, Spatial Policy 5 and Transport Policy 1).

- 4.0 Assessment
- 4.1 The proposal will increase the thermal efficiency of the building, thus supporting its continued use and maintenance and will remove an element which is neither original nor attractive and which contains asbestos.
- 4.2 The proposal was discussed with the Assistant Registered Buildings Officer (ARBO) who provided very helpful advice and concluded that the current roofing material - corrugated sheeting - to be the historically correct finish for the roof, noting that the structure was designed for a finish of this type. He recommended perhaps a green colour but had no objection to the proposed Merlin Grey.
- 4.3 The ARBO also reminded us of the historical importance of the building and that any unsympathetic alterations could result in further requests to re-assess the building for Registration although considered that the proposed replacement roof finish not to be unsympathetic.
- 4.4 It is important that this building is weather tight, water proof and as thermally efficient as it can be to ensure its continued use and maintenance and what is proposed will achieve all of these requirements, ensuring that the building is used and consequently that it remains well maintained and in good repair.
- 4.5 The sheeting has been sourced to try to be as close to the original metal roofing as possible and is arguably better than what exists which is cement sheeting and which contains asbestos.
- 4.6 We believe that the proposed replacement roofing will result in a structural and visual improvement to the building, complying as closely as possible and practicable with Environment Policy 34 and ensuring the continued use and presence of an important building in the Island’s capital City, in accordance with the Strategic Aim, Strategic Policies 1, 2, 3, 4, 5 and 10, General Policy 2, Spatial Policy 5. Transport Policy 1 and Environment Policies 42 and 43 and in full accordance with the Area Plan proposals.

Sarah Corlett 30.10.23

---

*Data sourced from the Isle of Man public planning register under the [Isle of Man Open Government Licence](https://www.gov.im/about-this-site/open-government-licence/).*
*Canonical page: https://planningportal.im/a/56869-braddan-wool-control-replacement-roof/documents/1109390*