**Document:** Officer Report **Application:** 25/91220/B — Replacement of existing slate roof with new slate roof and air permeable underlay, and installation of new lead hips, ridges, box and valley gutters in association with PA25/01223/CON RB179 **Decision:** Permitted **Decision Date:** 2026-03-05 **Parish:** Braddan **Document Type:** report / officer_report **Source:** https://planningportal.im/a/96384-braddan-douglas-castle-formerly-harold-tower-replacement-roof/documents/1590746 --- # Officer Report **Application No.:** 25/91220/B **Applicant:** Mr Ryan Douglas **Proposal:** Replacement of existing slate roof with new slate roof and air permeable underlay, and installation of new lead hips, ridges, box and valley gutters in association with PA25/01223/CON RB179 **Site Address:** Douglas Castle Formerly Harold Tower Fort Anne Road Douglas Isle Of Man IM1 5BN Senior Registered Buildings Officer: Tom Sinden **Expected Decision Level:** Officer Delegation **Recommended Decision:** Permitted **Date of Recommendation:** 27.02.2026 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. This application has been recommended for approval for the following reason. The application is judged to meet the statutory test within section 16 of the Act as the replacement roof and leadwork are such that the building's special architectural and historic interest would be preserved. The proposals are also considered to accord with Strategic Policy 4, General Policy 2 and Environment Policies 32 and 34 as the special interest of the registered building would be protected and preserved, the works would use traditional materials, and the character of the existing property and surrounding landscape would be respected. The application is therefore judged to be acceptable. Plans/Drawings/Information; This decision relates to drawings Q2202-01 and Q2202-02, together with the other supporting information received 18.12.2025. Right to Appeal Right to Appeal: Douglas City Council should not be awarded the Right to Appeal as they have not submitted comments that contain a relevant objection. ## Officer’s Report ### 1.0 THE SITE 1.1 The site is Douglas Castle, formerly named Harold Tower. The property is entered on the Protected Buildings Register at RB 179. The building is a mid-19th Century villa, possibly originally a folly, with crenelated towers in a Romantic Gothic style. ### 2.0 THE PROPOSAL 2.1 The application seeks approval for the replacement of the existing slate roof with new slate roof and air permeable underlay, together with the installation of new lead hips, ridges, box and valley gutters. The application is concurrent with registered building consent application 25/01223/CON. ### 3.0 PLANNING STATUS AND POLICY 3.1 The Site is not located within a conservation area and is not located within a flood risk for tidal and river flooding. The house is not located in an area of surface water flooring although some of the grounds are identified as a low risk of surface water flooding according to the D.O.I. Flood Risk Viewer. 3.2 National policy: THE ISLE OF MAN STRATEGIC PLAN 2016 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; General Policy 2 states: "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: - b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the space around them; - c) does not affect adversely the character of the surrounding landscape or townscape; - 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 adverse effect on road safety or traffic flows on the local highways; - j) can be provided with all necessary services" and Environment Policy 32: Extensions or alterations to a Registered Building which would affect detrimentally its character as a building of special architectural or historic interest will not be permitted. Environment Policy 34: In the maintenance, alteration or extension of pre-1920 buildings, the use of traditional materials will be preferred. 3.3 Planning Policy Statements: 1/01 Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man ## - POLICY RB/3 ## - POLICY RB/4 USE ## - POLICY RB/5 ALTERATIONS AND EXTENSIONS ### 4.0 OTHER MATERIAL CONSIDERATIONS 4.1 TOWN AND COUNTRY PLANNING ACT 1999 S16 Registered buildings: supplementary provisions (3) In considering — - (a) whether to grant planning approval for development which affects a registered building or its setting, or - (b) whether to grant registered building consent for any works, the relevant Department shall have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses. ### 5.0 PLANNING HISTORY 5.1 The following applications have been determined in respect of the property:Reference Number: 21/00245/GB Status: Permitted Proposal: Demolition of existing pantry extension and the erection of a new tower and extension to create additional living accommodation (in association with 21/00246/CON) Reference Number: 21/00246/CON Status: Permitted Proposal: Registered Building consent for the demolition of existing pantry extension and the erection of a new tower and extension to create additional living accommodation (in association with 21/00245/GB) Registered Building Nos. 179 Reference Number: 20/00467/CON Status: Refused Proposal: Registered Building consent for alterations and extension to roof to create observatory room (in association with PA 20/00466/GB) Registered Building Nos. 179 Reference Number: 20/00466/GB Status: Refused Proposal: Alterations and extension to roof to create observatory room (in association with PA 20/00467/CON) Reference Number: 08/00660/B Status: Permitted Proposal: Erection of a detached dwelling and garden store Reference Number: 08/01951/B Status: Permitted Proposal: Erection of a detached dwelling and garden store (comprising amendments to PA 08/00660B) Reference Number: 09/01852/GB Status: Permitted - Proposal: Erection of a replacement sun lounge (comprising amendments to 08/01678/GB) (In association with 09/01853/CON) Reference Number: 09/01853/CON Status: Permitted - Proposal: Erection of a replacement sun lounge (comprising amendments to 08/01679/CON) (RB no 179 in association with 09/01852GB) Reference Number: 08/01678/GB Status: Permitted Proposal: Construction of a swimming pool structure enclosing existing external pool and erection of a replacement sun lounge (In association with 08/01679CON) Reference Number: 08/01679/CON Status: Permitted Proposal: Registered Building Consent for the construction of a swimming pool structure enclosing existing external pool and erection of a replacement sun lounge (Registered Building no 179 in association with 08/01678GB) Reference Number: 09/00582/B Status: Permitted Proposal: Construction of a replacement firefighting pump house and pipeline Reference Number: 05/92362/B Status: Permitted Proposal: Erection of a conservatory to rear elevation ### 6.0 REPRESENTATIONS 6.1 Douglas City Council - No objections (12.1.2026). 6.2 Manx National Heritage, and DEFA Forestry were consulted on 30.12.2025. At the time of writing this report (27.2.2026), no comments have been received and it is therefore assumed that these consultees have no objections to the application. ### 7.0 ASSESSMENT Statutory Test 7.1 Section 16 of the Act requires that when considering whether to grant registered building consent, the Department must "have special regard to the desirability of preserving the building or its setting or any features of special architectural or historic interest which it possesses." In this instance, the application proposes replacement of the existing slate roof with new slate roof and air permeable underlay, together with the installation of new lead hips, ridges, box and valley gutters. Having reviewed the submitted information, it is clear that there are a number of areas of the existing roof that are in need of repair and are currently causing damage to the building's historic fabric below (both externally and internally). The proposals within this application are seeking to remedy these issues and afford long-term protection to the property. As such, the proposals are considered to meet the tests within section 16. Policy Tests 7.2 As per section 7.1 above, the application seeks to repair and upgrade the property's roof. The replacement slate roof covering, together with leadwork as detailed in the supporting information, are considered to be in a material and form that would respect the special interest of the registered building. As such, the proposals are judge to protect and preserve the registered building and respect the character of the existing property and surrounding landscape. ## CONCLUSION 8.1 The application is judged to meet the statutory test within section 16 of the Act as the replacement roof and leadwork are such that the building's special architectural and historic interest would be preserved. The proposals are also considered to accord with Strategic Policy - 4, General Policy 2 and Environment Policies 32 and 34 as the special interest of the registered building would be protected and preserved, the works would use traditional materials, and the character of the existing property and surrounding landscape would be respected. The application is therefore recommended for approval. ### 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: - applicant (in all cases); - 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): - any appellant or potential appellant (which includes the applicant); - the Department of Environment, Food and Agriculture, the Department of Infrastructure and the local authority for the area; - any other person who has submitted written representations (this can include other Government Departments and Local Authorities); and - in the case of a petition, a single representative. 9.5 The Department of Environment Food and Agriculture is responsible for the determination of planning applications. As a result, where officers within the Department make comments in a professional capacity they cannot be given the Right to Appeal. I can confirm that this decision has been made by the Head of Development Management in accordance with the authority afforded to that Officer by the appropriate DEFA Delegation and that in making this decision the Officer has agreed the recommendation in relation to who should be afforded interested person status, and/or rights to appeal. Decision Made : Permitted Date : 27.02.2026 Determining Officer Signed : S BUTLER Stephen Butler Head of Development Management Customer note This copy of the officer report reflects the content of the office copy and has been produced in this form for the benefit of our online service/customers and archive record. --- *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/96384-braddan-douglas-castle-formerly-harold-tower-replacement-roof/documents/1590746*