**Document:** Planning Statement
**Application:** 25/91100/B — Change of use from guesthouse to House in Multiple Occupation with 14 bedrooms, including the erection of secure bicycle and bin storage
**Decision:** Permitted
**Decision Date:** 2026-02-20
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/95832-douglas-wavecrest-12-empress-dwelling-change-of-use/documents/1143906

---

# Planning Statement

## Planning Statement for Change of Use Application for Guesthouse (Class 3.1) to House in Multiple Occupation (Class 3.5), Wavecrest, Empress Terrace, Central Promenade.

![A low-angle exterior photograph of a large, white, multi-story building with Victorian-style architecture, situated on a slope with parked cars in the foreground.](https://images.planningportal.im/2025/12/482242.jpg)

By

Cornerstone Architects Ltd

79 Parliament Street

Ramsey

Isle of Man

IM8 1AQ

- 2

Wavecrest, a former guest house (Class 3.1) is located on Empress Drive, off Central Promenade.

The property is five storeys and is accessed via a stepped approach from Empress Terrace. Most windows are timber sliding sash, with the some having been replaced with a uPVC casements as part of sporadic maintenance of the building.

Planning History:

- 86/01378/B - Alterations to install external fire escape and emergency exit. Permitted
- 87/01385/C - Change of us from guest house to office accommodation. Refused Proposal

The applicant seeks a change of use to turn the former guest house, Wavecrest (Class

- 3.1) into a House in Multiple Occupancy (HMO) (Class 3.5). The proposal will provide 14 en-suite bedrooms and a separate managers apartment. No works to the external fabric of the building are proposed as part of this change of use application. There is however an ongoing fabric review which will require repairs and redecoration to the external finishes of the building. The applicant will deal with the existing windows under separate cover.

Internally some changes are required to the layout to improve the accommodation space and to create a managers apartment as indicated on the submitted drawings. As part of this process, the Environmental Protection Unit of Department of Environment, Food and Agriculture have been consulted to ensure the proposed is in accord with requirements for a HMO as set out in the Housing (Standards) Regulations 2017. The proposal meets these criteria.

Furthermore, consultation has taken place with the Isle of Man Fire & Rescue Service as part of the design process to ensure the layout is compliant with the Fire Precautions (Houses in Multiple Occupation and Flats) Regulations 2016. Formal responses are awaited from the IOMFRS although the proposals meet the written requirements. Externally, a secure cycle store and standalone Sheffield bike stands are proposed to ensure each room is provided with at least one cycle space. A new secure bin store, accessed at street level from Empress Terrace is proposed. A secure bin store is vital to prevent refuse bins obstructing the footpath or highway when left unattended. Refuse capacity has been confirmed through prior consultation with the Douglas City Council.

### Planning Policy & Constraints

![A planning site location map displaying zoning areas and a red dot indicating the specific application site near a coastline.](https://images.planningportal.im/2025/12/7100260.jpg)

![A location map showing the site context with surrounding roads like Marathon Road and Empress Drive, featuring purple highlighted zones and a green boundary area near the coast.](https://images.planningportal.im/2025/12/7100261.jpg)

The site lies in an area of mixed use as identified on the Area Plan for the East and is located within the Douglas Promenades Conservation Area.

## Location of Wavecrest on Map 4 from the Area Plan for the East

There are no registered trees located on site. Wavecrest is outside of the area at risk of tidal flooding and surface water flooding as identified on the IOM Flood Risk Map.

## Extract from the Isle of Man Flood Risk Map

Relevant policies: Tourism Proposal 1 from the Area Plan for the East:There is a recognised need for the renewal of the Island’s hotel offer through investment in existing stock and some new hotel provision. Planning applications for the conversion of hotels in the eastern area to other uses will not normally be permitted unless it can be demonstrated that the premises do not provide a sufficient standard of accommodation and upgrading the facility would not be feasible.

It is regrettable but the accommodation does not meet the required standard for tourist use in this context.

## Strategic Policy 12:Favourable consideration will generally be given to proposals for improving the quality and condition of the existing housing stock and for the creation of flats by conversion of redundant boarding houses, and vacant or under-used space above commercial premise.

The proposal addresses the published need for additional HMO accommodation, and the building can be readily converted as set out in the application.

## Environment Policy 35:Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area and will ensure that the special features contributing to the character and quality are protected against inappropriate development.

The applicant is committed to improving the external appearance of the building in its setting.

## 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.

The applicant has reviewed the options and the conversion to HMO meets with his strategy and fulfils a gap in the accommodation market. The use is compatible with adjoining properties.

### Transport

No dedicated parking facilities can be provided to the occupants of Wavecrest. Empress Terrace is a one-way road, with informal on street parking to both sides of road. Due to the nature of the town centre site, there is no scope to provide any offroad parking within the curtilage of Wavecrest. The property is afforded good public transport links, with north and south bound bus stops within a 150m of the front door of the Wavecrest.

Additionally, the Promenade shared surface provides excellent active travel opportunities for the occupants to commute via bicycle or walking to places of work.

## Amenity

Although private amenity space at Wavecrest is limited to a small terrace at the front of the property, its city centre location provides convenient access to Douglas Beach, the Promenade, Villa Marina Gardens and Summer Hill Glen. These facilities are all within walking distance and offer ample open space provision for future occupants.

Summary There is a clear need for this type of accommodation on the Island, as demand has increased fivefold over the last eight yearsi. The existing building is no longer suitable or desirable for use as a guest house. Modern standards required for new guest houses or hotels cannot be achieved within the existing property. No dedicated guest drop-off point can be provided at the entrance due to existing highway constraints, and disabled access cannot be accommodated either to or within the building.

New hotel provision has been delivered through major developments in the city centre, such as the 80-bedroom hotel at Villiers Square, Fort Street, Douglas, meaning any loss of hotel accommodation at this site can be offset. Further new hotel developments include the under construction 44-bedroom hotel at the former Salvation Army Citadel & the 85-bedroom Premier Inn, completed in June 2019.

We acknowledge that no allocated parking can be provided; however, this is inherent to many city centre residences. The central location offers excellent opportunities for active travel, supporting the long-term vision set out in the Active Travel Strategy: “to be an Island where cycling and walking are normal and realistic transport choices for people of all ages and abilities.”

A change of use will allow the property to be converted into an HMO, which will be properly maintained, improving the building’s condition and extending its usable lifespan. This approach will also prevent another city centre building from falling out of use and becoming dilapidated.

We would therefore request that the application is supported as the existing building is no longer suitable for use as a guest house or hotel. The proposal will bring the vacant building back into use and, with continued maintenance will help preserve the building within the Douglas Promenade Conservation Area while providing much needed accommodation.

## References

i https://www.iomtoday.co.im/news/isle-of-man-sees-sharp-rise-in-residents-living-in-houses-ofmultiple-occupation-840497

---

*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/95832-douglas-wavecrest-12-empress-dwelling-change-of-use/documents/1143906*
