**Document:** Lighting Mitigation Summary Report
**Application:** 23/10105/AIR — Information in relation to condition 14 for PA 22/00549/B for Lighting Mitigation
**Decision:** Permitted
**Decision Date:** 2023-10-10
**Parish:** Braddan
**Document Type:** report / planning_statement
**Source:** https://planningportal.im/a/27306-braddan-information-relation-condition/documents/1589862

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# Lighting Mitigation Summary Report

### Lighting Mitigation Summary

![drawing from page 1](https://images.planningportal.im/2023/09/7079315.png)

Planning Condition 14, Reference 22/00549/B Development of the former IOM Holiday Camp, Switzerland Road, Douglas, Isle of Man

## King Gaming Campus

### Contents

Glossary............................................................................................................................................. 2 Appendices ........................................................................................................................................ 2

- 01. Introduction ........................................................................................................................... 3

- 01.01 The Proposed Development ................................................................................................ 3
- 01.02 Planning Conditions ............................................................................................................. 3
- 01.03 Background Information / Bat Protection and Lighting ....................................................... 3
- 01.04 Background Information / Lighting in the Context of nearby identified Registered Buildings / Conservation Areas. ........................................................................................................... 4
- 01.05 Ecology Vannin Consultancy Input ...................................................................................... 5

- 02. External Lighting Aspects ........................................................................................................ 6

- 02.01 Details provided as Part of The Planning Submission .......................................................... 6
- 02.02 Further Details / Design Development of External Lighting................................................. 6
- 02.03 External Lighting Plans and Calculations ............................................................................. 7

- 03. Internal Lighting Aspects ........................................................................................................ 8

- 03.01 Details provided as Part of the Planning Submission ........................................................... 8
- 03.02 Further Details / Design Development of Internal Lighting ................................................. 9
- 03.03 Sectional Consideration and Further Mitigation ............................................................... 11
- 03.04 Internal Lighting Calculations (Level 1 and 2 Office Areas) ................................................ 12

- 04. Lighting in The Context of nearby Registered Buildings and Conservation Areas .......................... 13

- 04.01 Further Correspondence ................................................................................................... 13
- 05. Summary ............................................................................................................................. 13

#### Glossary

CEMP Construc on Environmental Management Plan DEFA Department of Environment, Forestry and Agriculture EVC Ecology Vannin Consultancy (Formerly Manx Wildlife Trust Consultancy) PEAR Preliminary Ecological Appraisal report

#### Appendices

- Appendix 01 Summary of Bat Protec on Measures by Ecology Vannin Consultancy
- Appendix 02 External Ligh ng Scheme and Light Calcula ons provided by Trilux
- Appendix 03 Reflected Ceiling Plans for L1 and L2 Office Floors
- Appendix 04 Internal Ligh ng Scheme and Light Calcula ons provided by Trilux

###### Note that the Appendices are provided as a separate document to reduce file size.

#### 01.Introduc on

##### 01.01 The Proposed Development

The development comprises the crea on of a Parkland Campus facility consis ng of a head-quarters office building with restaurant, café and collabora ve working areas as well as 66 associated staff accommoda on units with surrounding access routes and landscaping.

Excel Architectural are the main designers of the scheme, Excel Group has been appointed as the main contractor for this project.

##### 01.02 Planning Condi ons

The Planning Application for the King Gaming Campus on the Former Isle of Man Holiday Camp on Switzerland Road (Application 22/00549/B) for the Creation of a Parkland Campus facility comprising of a head-quarters office building with restaurant, café, collaborative working areas and 66 associated staff accommodation units with associated landscaping was approved in the Planning Committee on the 22nd of August 2022 and received formal approval following appeal on the 29th of June 2023.

Condition 14 of the Approval Notice states the following:

Prior to the commencement of the development hereby approved a strategy for lighting within the site must be submitted to and approved by the Department and the development must be undertaken in full accordance with these approved details. This strategy shall deal with internal and external lighting and to the potential impacts therefrom including the position, number, type and intensity of lighting throughout the site and any other measures required to mitigate any potential impacts therefrom to ensure protection of bats/birds and to ensure appropriate protection of the nearby identified Registered Building/Conservation Area and shall include a timetable for implementation of the scheme. The approved Scheme shall be fully adhered to and retained thereafter. There shall be no external illumination and no additional lighting of any kind within the building other than that approved within the approved strategy for lighting.

Reason: To ensure adequate protection of protected species and appropriate protection of the visual amenities of nearby identified Registered Buildings / Conservation Areas.

##### 01.03 Background Informa on / Bat Protec on and Ligh ng

- As part of the overall site investigations leading up to the planning submission, bat activity surveys both for winter hibernation and summer activity (breeding season) were conducted at the site by the Manx Wildlife Trust. Bat activity and winter hibernation report were issued in July 2022 and are available as part of the Planning Application Documentation.

The purpose of the survey was to ascertain the presence of bats and their use of the survey site, to prevent any offences in relation to the Isle of Man Wildlife Act 1990 (as amended) and so that potential impacts from development can be mitigated.

The key findings of these surveys were used to inform a bat mitigation plan comprise:

• Foraging and commuting by Common Pipistrelle (Pipistrellus pipistrellus) comprised 99% of all recordings taken)

Key considerations in the mitigation are to address the provision of continued use of the survey site for commuting and foraging at appropriate heights, the reduction of light spill to acceptable levels and compensatory provision of wetland as a food and drinking resource.

- • Low level commuting and foraging activity by Leisler’s Bat (Nyctalus leisleri)
- • Low numbers of bat passes (<10) Brown long-eared Bat Plecotus auritus, Daubenton’s Bat Myotis daubentoni and Soprano Pipistrelle Pipistrellus pygmaeus.

The mitigation measures proposed at the time were also included in the report and are added for reference in Appendix 01 of this Document. Recommendations for enhancement to achieve ‘no net loss’ of biodiversity were also provided as part of this submission and followed the recommendations outlined in the Preliminary Ecological Appraisal Report (PEAR) undertaken in July 2021.

The Design and Access Statement submitted with the Planning Application also outlined some strategic thoughts for external lighting aspects which are summarised under Items 2 and 3 below.

##### 01.04 Background Informa on / Ligh ng in the Context of nearby iden fied Registered Buildings / Conserva on Areas.

The visual impact on the conserva on area was also considered during the design development process and the wider views were produce to show the building in the context.

- At the request of the Principal Registered Buildings Officer, two night  me / dusk views were also submi ed which illustrated the overall ligh ng scheme of the building in the context. One of the views is included below for reference and illustrates the sensi ve and rela vely warm and low level ligh ng proposed.

Photomontage 1A of Douglas Bay (submi ed as part of the Planning applica on)

![photograph from page 4](https://images.planningportal.im/2023/09/7079317.jpg)

The Heritage Statement produced by Wardell Armstrong and submi ed as part of the planning submission referred to the nigh me views (paragraphs 6.9.3 and 6.9.4) and concluded in Paragraph 8.1.2 that

Impacts would … be limited to the Falcon Cliff Hotel and Douglas Promenade Conserva on Area (…)and (…) are an cipated to result in less than substan al harm to their heritage significance, with the principal elements of interest held by each asset conserved.

The Principal Registered Buildings Officer generally concurred with the findings of the Heritage Report and added the following note as part of his Consulta on Report (dated 04/08/2022):

The Heritage Assessment also contained requested night- me visualisa ons, given the materiality of the proposals, it is also important that the night- me illumina on of the building either via internal or external means of illumina on is controlled, as the level of illumina on will also impact upon extent of poten al harm cause to the se ng of the iden fied assets. This issue has been acknowledged within the submi ed informa on and should also be controlled via condi ons to minimise the poten al impact of the proposals.

Given the posi oning of the proposed principal building its poten al impact could be increased by inappropriate adver sements, all forms of adver sement upon this building should be prohibited par cularly any large scale illuminated le ering or symbols placed upon the roof or seaward eleva on should be wholly prohibited.

Further considera ons with regards to this aspect were provided as part of the general communica on during the planning process and are further summarised under Item 4 below.

##### 01.05 Ecology Vannin Consultancy Input

Ecology Vannin Consultancy (EVC, formerly MWT Consultancy) have contributed to various aspects in this document.

The advice has been provided by Adam Denard, Senior Ecologist for Ecology Vanin consultancy who has been involved in the project form the vary outset. His Biography is included below.

###### Biography:

Adam Denard BSc (Hons) MIEEM has been a professional ecologist for over 10 years, with par cular emphasis on recording and assessing habitats in England and the Isle of Man for their poten al to support protected species.

Adam regularly produces professional ecological reports within the Isle of Man planning system. This includes Preliminary Ecological Appraisals, Impact Assessments and specialist surveys for breeding and wintering birds, bats, rep les and amphibians.

#### 02.External Ligh ng Aspects

##### 02.01 Details provided as Part of The Planning Submission

As outlined in the Design and Access Statement submi ed with the applica on (refer to Page 61 of the DAS), the inten on has always been to keep the external ligh ng for the campus low key in an effort to prevent light spill onto the adjacent woodland. Light levels were to be kept to the minimum required for the various uses and lights are limited to the areas where they are necessary.

An indica ve external ligh ng plan (Drawing 2108-PL-3007) was submi ed as part of the Planning Applica on and further details and an indica ve light spill overview plan was subsequently provided as an appendix to the Bat Ac vity Report in July 2022.

This indicated

- - LED column lights for the shared surface and parking areas to achieve the required light levels. Lighting with custom fitting optics and baffles were proposed to ensure that light spill onto adjacent trees is limited. Lights had to be located on the building side of the road to avoid impact on the rots of the existing site boundary trees.
- - Low Level bollard lights to the pedestrian routes through the site with the fitting type and spacing again selected to provide adequate light levels while avoiding light pollution.
- - Low level wall recessed fittings to ramp and stepped areas for safety reasons.
- - Building mounted lighting in the form of recessed downlights or wall mounted lights to the main entrances of the accommodation and the commercial buildings with lighting to escape exits and secondary entrances controlled by PIRs.

The Design and Access Statement further outlined that all

- - All lighting will be energy efficient LED lighting
- - Lighting will be generally be controlled by timeclock and photo-cells to prevent operation during daylight hours and PIRs will be used where lighting is only required at intervals to further minimise light pollution and spill.
- - Decorative lighting and up-lighting has been minimised to a small area right in front of the main office entrance.

and

- The ground floor terrace of the commercial building will be lit only from within the building to again avoid additional light spill in this sensitive area.

- 02.02 Further Details / Design Development of External Ligh ng The outline proposals developed for the planning applica on have remained unchanged.

The proposals have been developed in more detail with the MEP Consultant and a preferred ligh ng supplier has been selected. The detailed proposal document from Trilux is included in Appendix 02 of this document and includes ligh ng calcula ons for the various areas as well as details of the proposed light fi ngs.

It should also be noted that Trilux is a reputable ligh ng supplier and they have been ac vely involved in developing products which are insect friendly as well as sustainable and adaptable to incorporate cowls and reflectors to suit the various requirements.

The below outlines the main considera ons which have been incorporated in the proposals for this project:

- 1. Color Spectra The attraction of light to insects can be significantly reduced by choosing the right light color or spectral composition. In general, short-wave light in the blue range (cold white) attracts moths and the like more than warm white light (≤ 3,000 Kelvin). In this location, avoiding blue range light which is a disturbance to bats was the main consideration and light fittings with 3,000 Kelvin have been selected.
- 2. Smart Dimming Time and sensor controlled dimming saves energy and money. But insects also benefit from light management and dimmable lights due to fewer nocturnal disturbances. This will again be incorporated on this project.
- 3. Light control A well thought-out luminaire design (reflectors and lenses) directs the light to where it is needed, without emitting it into the upper hemisphere. This increases the efficiency of the lamp and reduces light pollution at night. Appropriate light fittings with reflectors and lenses as and where required have again been selected for this project.
- 4. Housing A high degree of protection of at least IP54 prevents insects from entering the housing. The temperature of the housing should not exceed 50°C to avoid damaging or killing insects. This has again been incorporated in the proposals for this project.

##### 02.03 External Ligh ng Plans and Calcula ons

The indica ve Ligh ng Plan has been developed further and op mised by Trilux but has remained largely unchanged, with some detailed aspects outlined below:

- - The lighting positions have remained similar but with the confirmation of light fitting type and output, the number of columns and bollards have reduced in numbers while still achieving a compliant lighting classification.
- - The roadway and footpath/walkways have all been calculated to P4 lighting classification.
- - The column mounted luminaires have been set at 5m height and utilise a full cut off (no upwards light) LumiStreet Gen2 at 0 degree tilt with 3000K colour temperature for bat protection.
- - LED Bollard lighting for the perimeter footpath/walkways, wall mounted luminaires near doors and exits and recessed under canopy luminaires (providing 50 lux) at the entrances are all again set at 3000K.

While their light calcula ons are provided separately for the different areas, they overall support the Exterior Ligh ng Heatmaps and indica ve illustra ons included in the previous submission which indicate that the majority of the woodland edge area has been kept as unlit as possible. The previously provide image is included below for reference.

Previously provided illustra on of Exterior Ligh ng Heatmap

#### 03.Internal Ligh ng Aspects

##### 03.01 Details provided as Part of the Planning Submission

Details for the internal ligh ng were also reviewed in some depth and informa on was submi ed by MWT in the planning stages summarising the approach …

Bat Ac vity report included an indica ve drawing showing the expected light spill from internal areas around Block C in par cular.

An indica ve sec on drawing was included which illustrated the following:

- - The commercial building includes distinct areas on the different floors which will have different lighting requirements and aesthetics.
- - The lower ground floor and basement include secondary uses such as carparking and plant rooms only with all lighting PIRs and infrequently used. These areas have a predominantly solid brick facade with v-type ventilation louvres for carparking and plant areas which would result in very little light spill at the base of the building. The height of the base varies from ca 6.5m in the south corner where the ground falls away to ca 3m in the east and west corners, keeping the main flight path height of most bat species rela vely clear of direct light spill. At ground level in these areas, light levels would be expected to be very low but can’t be substan ate in lux level terms.
- - The ground floor and level 3 (south part) of the building are predominantly used for dining and staff break out areas – light levels in these areas would be kept relatively low to achieve a more comfortable dining and break out experience with indirect lighting used to supplement light levels locally.
- - Level 3 and 4 penthouse areas will also have low light levels with again indirect lighting used to supplement light levels locally.
- - The light temperature of any lighting used in these spaces would also generally be warmer (2500 to 2700K) which, as outlined in the Bat Activity report, further assist in reducing blue range spectrum light.

All these principles and considera ons have remained unchanged but have now been developed in further detail for the office floors 1 and 2 as outlined below.

![A technical site plan showing building footprints overlaid with a color-coded lighting contour map and legend.](https://images.planningportal.im/2023/09/7079318.png)

As also explained previously, the deep brise soleil canopies will protect the ground level from downward light spill. This was illustrated with an indica ve sec on, again included in the documents submi ed for the applica on.

Previously provided illustra on of Sec on at the base of the building

##### 03.02 Further Details / Design Development of Internal Ligh ng

During the appeal stages it became clear that the main area of concern for the Ecosystem Policy Officer are the office areas which require good ligh ng levels in order to provide a suitable working environment and to comply with workplace recommenda ons.

The reflected ceiling plans for these areas have been developed in more detail with the MEP consultant and with input from Ligh ng suppliers and Trilux have again provided detailed ligh ng calcula ons which illustrate the light levels on the office floors.

The detailed RCP layouts for levels 1 and 2, which are almost iden cal in layouts are included in Appendix 03 and a smaller par al enlarged plan is also included below.

The drawings illustrate the following:

- - Linear lights are proposed for all open plan office areas; the light types proposed are shown in the Trilux overview document.
- - The lighting calculations note the 3000K light temperature, which is relatively warm for an office environment (4000 to 4500K more commonly), is proposed throughout and will, as explained in the previous points, avoid blue light as far as is possible.
- - The lighting has been positioned perpendicular to the façade, in line with the desking. The spacing has been optimised based on the 3000K light temperature.
- - Light levels have been developed to CIBSE standards and the output of the lights will be designed to meet the required light level as closely as possible.
- - No decorative or edge lighting has been included in any of the open plan office areas, only the linear lights required to light the desking and cove lighting along the core and corridor areas which will provide lower light levels for circulation spaces, shown in yellow in the above RCP Plan.

![A technical architectural section drawing showing lighting analysis overlays with text annotations regarding lux levels for a terrace and interior spaces.](https://images.planningportal.im/2023/09/7079319.png)

Par al Reflected Ceiling Plan – Level 1 The below plan shows the lighting heat map which has been provided by Trilux overlaid with the partial ceiling plans. Par al Reflected Ceiling Plan with Ligh ng heat map – Level 1

![This image displays a technical architectural drawing of an open-plan office interior, detailing ceiling types, lighting fixtures, and furniture layout.](https://images.planningportal.im/2023/09/7079320.png)

![A technical engineering diagram showing a lighting analysis simulation with color-coded intensity zones overlaid on a grid, alongside a partial architectural floor plan.](https://images.planningportal.im/2023/09/7079321.png)

It should be noted that the reflected ceiling plans and the ligh ng in the atrium space will be different, sla ed  mber ceilings with circular lights, direc onal in some areas, are proposed and light levels overall will likely be locally higher as is illustrated in the Trilux document under item 2.1.1. This space is however facing the main entrance area which will need to be well lit, not the more sensi ve woodland edge areas and was therefore considered less of a concern.

A ligh ng control system will again be incorporated which will ensure lights come on gradually as light levels fade externally and PIRs will be in place throughout the office areas to ensure lights are only on in the office areas when occupied.

##### 03.03 Sec onal Considera on and Further Mi ga on

The floor sec ons have been developed in conjunc on with the reflected ceiling plans and it should be noted that while suspended linear ligh ng was proposed in the earlier design stages, the linear lights are now flush in the ceiling and posi oned higher in the space.

The ligh ng heat map shows how the light levels are tailing off towards the façade, resul ng in light level of less that 100 lux adjacent to the façade line. If the ligh ng calcula on area where to be extended, they would further reduce on the canopy projec on areas and result in very low light levels at the edge of the 2m wide canopy areas. This illustrates that direct downward lights from the various floors would not reach the ground level areas.

The sec on below shows the current floor to floor height, the light posi on and indicates the gradient of the ligh ng on the working surface.

Sec on through level 1 with Ligh ng heat map

![Architectural section drawing detailing an open plan office area with automated blinds and recessed linear lighting.](https://images.planningportal.im/2023/09/7079322.png)

As concerns about light spill could not be rules out en rely, it was suggested that the blinds, which will be provided in all the open plan areas on both floors (level 1 and 2) as well as on the south facing ground floor eleva ons to reduce glare and solar gains and which will be automated, could also be used to further minimise light spill into the sensi ve woodland edge areas.

The blinds could be automated and, like ligh ng controls, be linked to daylight levels outside and set to come down at dusk to a height of to approx. 1.5m above floor level. This height would s ll allow users a visual connec on to outside when seated but may assist in further minimising light spill. Bringing the blinds down to a lower level could also be considered if necessary.

This approach would be reviewed when the façade installa on is completed, but before the building is occupied and the requirement for the blinds to be closed could then be ascertained and the exact level of closure could be determined.

The internal ligh ng of the building will equally be energy efficient LED ligh ng and will be controlled by  meclock and photo-cells to prevent opera on during daylight hours or when the building areas are not in use. PIRs will be used where ligh ng is only required at intervals to further minimise light pollu on and spill.

##### 03.04 Internal Ligh ng Calcula ons (Level 1 and 2 Office Areas)

Detailed ligh ng layouts for a typical office floor plan which would apply to levels 1 and 2 of the building have again been provided by Trilux and are a ached in Appendix 04 of this document and again also give an indica on of the details of the selected ligh ng types.

It should be noted that the ligh ng supplier for these areas will not be appointed for some  me as the installa on date is ca 2.5 years in the future, but the drawings illustrate the main principles of the ligh ng design and should there be any devia ons, this document would be updated accordingly.

Reflected ceiling plans for the same two levels produced by HofmanDujardin, the interior architects for the building are included in Appendix 03 of the document and show the full extent of the floor plate.

#### 04. Ligh ng in The Context of nearby Registered Buildings and Conserva on Areas

##### 04.01 Further Correspondence

In August 2022, the applicant responded to the Principal Registered Buildings Officer comments (refer to item 01.04 above) and noted that the avoidance of illuminated signage to the bay facing eleva ons goes hand in hand with the avoidance for light pollu on on these sides. As noted above no decora ve lights or other illumina ons are included along the floor edges on the typical office floors of the commercial building and the same will apply to all other floors.

Any illuminated signage would in any case require a separate Adver sing Applica on which would not be permi ed in this loca on and under the circumstances.

The client would like to keep the op on open of having some signage, possibly with illumina on, to the entrance / drop off area, where it would not impact on the wider se ng as it is inner facing and where light levels will generally be higher to allow for safe access and egress.

#### 05. Summary

We trust that the above sufficiently illustrates the considera on that has been given to the ligh ng layouts in an effort to mi gate against impact on wildlife in general and protected species in par cular as well as the visual ameni es of nearby iden fied Registered Buildings / Conserva on Areas.

Ligh ng aspects for the construc on phase have been considered separately and are outlined in the Construc on Environmental Management Plan submi ed for Condi on 12.

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*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/27306-braddan-information-relation-condition/documents/1589862*