DEC Officer Report

Application No.: 24/00674/B Applicant: Elliott Storage Proposal: Erection of purpose built self storage facility over two levels with associated car parking and fencing Site Address: Plot 8 Middle River Industrial Estate Pulrose Road Douglas Isle Of Man Planning Officer: Paul Visigah Photo Taken: 04.09.2024 Site Visit: 04.09.2024 Expected Decision Level: Officer Delegation Recommended Decision: Permitted Date of Recommendation: 11.10.2024 _________________________________________________________________

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. The proposed storage containers as shown on drawing referenced 125/101 Rev D, shall be coloured dark green and retained as such thereafter. Reason: In the Interests of visual amenity of the site and surrounding area
• C 3. The proposed perimeter fencing along the site boundary and gates as shown on drawing referenced 125/101 Rev D, shall be coloured grey (similar to the adjoining sites), and retained as such thereafter. Reason: In the Interests of visual amenity of the site and surrounding area
• C 4. No items of machinery or any equipment or other goods shall be kept outside of any containers, and all activities shall be undertaken within the containers as shown on Drawing 125/101 Rev D. Reason: In the Interests of visual amenity of the site and surrounding area.
• C 5. In the event that the containers hereby approved are not used or required for storage purposes for a period exceeding 12 months, the containers and fencing hereby approved shall be removed and the ground restored to its former condition within 18 months of its last use.

• Reason: This approval has been exceptionally approved solely to meet the storage need and its subsequent retention if left abandoned could result in an unwarranted visual impact.
• C 6. There shall be no retailing from the storage units.

Reason: For the avoidance of doubt, and to ensure the development takes place in accordance with the approved details.

• C 7. Notwithstanding the provisions of the Town and Country Planning (Use Classes) Order 2019, the use hereby approved shall be limited to storage.

Reason: For the avoidance of doubt, to ensure the development takes place in accordance with the approved details and in the interest of the local amenity.

• C 8. The car parking area hereby approved shall at all times be made available for the parking for visiting customers and shall be retained available for such use. No vehicle may be left overnight within the parking area. Reason: To ensure adequate parking is provided given the reduction in parking spaces.
• C 9. The development must be carried out in accordance with the recommended flood mitigation approaches identified in the Correspondence from the Applicants Agent received 01 July 2024, and retained as such thereafter.

Reason: To safeguard the amenities of prospective occupiers and to ensure the development complies with Environment Policy 10 of the Strategic Plan.

• C 10. Prior to the occupation of the development hereby approved, the bin storage and recycling collection points shall be provided in accordance with the approved plans (Drawing No. 125/101 Rev D) and shall be permanently retained thereafter and solely for the purpose of refuse storage.

Reason: In the interests of the appearance of the development and of the amenities of the area.

• C 11. No external lighting shall be installed unless in accordance with the details contained in the Proposed Lighting Plan (Drawing No 105), and shall be retained as such thereafter. Reason: To avoid and mitigate ecological impacts.
• C 12. The Bat and bird boxes proposed as part of the development are to be erected strictly in accordance with the Wildlife Mitigation Measures shown on Drawing No. 104, and retained as such thereafter. Reason: In the interests of biodiversity of the site/area.

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

Overall, it is considered that the proposal would comply fully with the zoning of the site which is for industrial use, and the overall proposed use is in keeping with the layout and general character of the site. It is also considered that the proposal by reason of the location, the availability of parking spaces and acceptable amenity impact on the neighbouring properties is considered to be acceptable. The development is, therefore, considered to comply with the requirements of Strategic Policies 1, 5, and 10, General Policy 2, and Transport Policies 4 and 7 of the Strategic Plan.

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

• o Planning Statement; and
• o Drawing No. 100 - Location and Site Plan Received 17 June 2024;
• o Agents Response to Consultees dated 1 July 2024.
• o Drawing No. 104 - Wildlife Mitigation Measures;
• o Drawing No. 105 - Lighting Plan; and
• o Drawing No. 106 - Root Protection Plan; Received 24 September 2024;
• o Drawing No. 102 - Visibility Splay;
• o Drawing No. 103 - Street Elevation;
• o Drawing No. 101 Rev D - Proposed General Arrangement;
• o Drawing No. 102 Visibility Splay; and
• o Drawing No. 103 Street Elevation; Received 27 Sep 2024. _______________________________________________________________

Interested Person Status

It is recommended that the following Government Departments should be given Interested Person Status on the basis that they have made written submissions relating to planning considerations:

• DOI Flood Risk Management ___________________________________________________________________

Officer’s Report

1.0 THE SITE - 1.1 The application site is a parcel of land which lies at the southern side of Middle River Industrial Estate, and beside the former Eastern Civic Amenity Site, situated on the southwestern side of the estate, and at the end of the primary road that serves the estate. The south-eastern boundary of the site bounds mature landscaping and trees, with the mature trees which run along the western edge of the main road serving the estate screening the site from the surrounding Douglas Golf Course on Pulrose Road which sits opposite the site. - 1.2 There are vertical bar railings form the boundary of the site with the former Eastern Civic Amenity Site to the south-west, as well as Plot 7 which sits north east of the site. The site area is generally flat and currently covered in wild grass.

2.0 THE PROPOSAL - 2.1 Planning approval is sought for Erection of purpose built self-storage facility over two levels with associated car parking and fencing. This purpose-built self-storage facility to the East of the island would comprise of 106 storage (shipping) containers. - 2.2 The proposed scheme would involve the erection of two floors of shipping containers on site which would measures about 46.2m along its longest elevation (north elevation), and 31.6m along its rear (east) elevation which would have four rows of shipping containers each measuring 6.58m long, separated by three corridoes measuring 2.7m, 1.8m, and 2.7m

• respectively. The elevation which directly abuts the estate road would measure about 15.1m comprising two rows of shipping containers separated by a 2.7m wide corridor.
• 2.3 The new structure would sit about 5.3m tall from the ground level to the top of its top, with stairway serving the storage spaces on the first floor. There would be no external cladding as the structures would retain their green cringle appearance. The perimeter of the site will be enclosed with industrial style fencing similar to adjacent fences.
• 2.4 There will be one large automatic vehicular gate placed along its front elevation which will be operated by a pin pad, and a single pedestrian maintenance gate to the rear of the site.
• 2.5 The new scheme would create a storage floor area of about 1551sqm which should require 15 parking spaces to meet the Strategic Plan parking requirement of 1 space per 100 square metres gross floor space, for Storage and distribution. 12 parking spaces have, however, been proposed for the site.
• 2.6 The applicants have provided a Planning Statement which states the following:

• 1. The running of the storage facility is to be operated mostly remotely and there are no plans to have any permanent staff on site, however maintenance staff would be attending the site, along with office-based staff working from another location.
• 2. The current facility in Jurby is providing employment for 3 members of staff, and should this expansion be permitted this number is likely to increase.
• 3. The current leasing records show that the facility would be providing storage facilities to a number of Retail, Construction/Tradesmen, Commercial Offices, Digital Entertainment, Event management companies and Fitness companies.
• 4. The provision of car parking spaces relies on the "Self Storage Association United Kingdom" document (Appendix B) "Traffic Patterns for Self Storage".

3.0 PLANNING POLICY - 3.1 Site Specific:

• 3.1.1 The site lies within an area designated as Industrial on the Area Plan for the East (Map 4 - Douglas), and the site is not within a Conservation Area. The site is largely not within a flood risk area, although the north-western section of the site has high likelihood of surface water flood risks. There are no registered trees on site, and the site is not within a Registered Tree Area.

3.2 Area: TAPE (2020)

• 3.2.1 The following parts of the Area Plan for the East are considered relevant:

• a. Employment Recommendation 1: A cross-government study could be carried out to identify opportunities to improve the management of existing Industrial Estates to minimise vacancy rates and to also identify opportunities to facilitate investment in new sites (including through the development of a Technology Park(s).
• b. Employment Recommendation 2: In the implementation of Employment Recommendation 1, consideration should be given to the identification of areas where:

• a) uses should be restricted to light industrial uses; or
• b) areas where 'bad neighbour' uses might be appropriate and consider the merits of safeguarded such areas for these uses.

• 3.3. National: STRATEGIC PLAN (2016)

• 3.3.1 Relevant Strategic Plan Policies:

• a. General Policy 2 - General Development Considerations.
• b. Strategic Policy 1 - Efficient use of land and resources.
• c. Strategic Policy 2 - Priority for new development to identified towns and villages.
• d. Strategic Policy 5 - Design and visual impact.

• e. Strategic Policy 6 - Major employment-generating development should be located in existing centres on land zoned for such purposes and identified as such in existing Local or new Area Plans.
• f. Strategic Policy 7 - Undeveloped land which is zoned in Local or Area Plans for industrial, office, or retail purposes will be retained and protected for such uses, except where those uses would be inappropriate or incompatible with adjoining uses.
• g. Strategic Policy 10 - development should promote integrated journeys, minimise car use and facilitate other modes of travel.
• h. Transport Policy 7 - Parking considerations/standards for development.
• i. Business Policy 1 - The growth of employment opportunities throughout the Island will be encouraged provided that development proposals accord with the policies of this Plan.
• j. Environment Policy 22 - deals with vibration, odour, noise and light pollution in relation to nearby properties.
• k. Environment Policy 4 - protects biodiversity (including protected species and designated sites).
• l. Transport Policy 1 - Requires new development to be close to existing public transport facilities and routes, including pedestrian, cycle and rail routes.
• m. Transport Policy 4 - New and existing highways which serve any new development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan.
• n. Transport Policy 7 - Parking standards.
• o. Other policies within the Strategic Plan which are considered relevant in the assessment of the proposal are; Infrastructure Policy 5, Community Policy 11, Community Policy 7 and Community Policy 10.
• p. Paragraph 9.2.4: Sites identified as suitable for Industry will generally also be suitable for the storage and distribution of goods, although, depending upon location with respect to other uses, the Department may restrict the goods stored by attaching the following condition: "The building(s) hereby approved may be used for storage and distribution. Approval does not extend to the use of the site for retail purposes or as a skip transfer station or for the storage or distribution of dangerous goods (as defined in the Road Traffic Act: Road Vehicles carrying Dangerous Goods (Maintenance and Use) Regulations 2000) or coal or items which could give rise to nuisance to adjacent land users by virtue of dust, noise or smell".

- 4.0 OTHER MATERIAL CONSIDERATIONS

4.1 Section 68 of the Flood Risk Management Act (2013) indicates that any published Flood Risk Management Plan and the extent to which the proposed development creates an additional flood risk are material considerations.

4.2 The Isle of Man's Biodiversity Strategy (2015 - 2025)

• 4.2.1 The Department's Biodiversity Strategy is capable of being a material consideration. It seeks to manage biodiversity changes to minimise loss of species and habitats, whilst seeking to maintain, restore and enhance native biodiversity, where necessary.

4.3 Traffic patterns for self-storage: Self Storage Association United Kingdom

• 4.3.1 On average there are less than 7 cars per 100 units, entering a site over the whole day. With customers staying an hour on average, most sites would only ever have 2 or 3 cars per 100 units on site at any given time.

• 4.3.2 There are rarely "visitors" to self-storage facilities. Self-storage units are not usually used for retail sales. While they can be used for storage of commercial goods, they are not sales offices' or administrative units. In fact most do not even have power to the units. This means there are no "visitors" to the site other than prospective customers. Vehicles within the site are primarily either loading or unloading goods.

• 4.3.3 Average vehicles entering per day during the regular access hours by centre size and immediate market area:

• o Number of self-storage spaces: Less than 100
• o Average Vehicles per day: 6.5

• 4.3.4 Average vehicles entering per day during outside of the regular access hours by centre size and immediate market area:

• o Number of self-storage spaces: Less than 100
• o Average Vehicles per day: 2.1

• Regular access hours are considered to be when the store is unmanned. This does vary from store to store but is typically 6pm -8am.

- 5.0 PLANNING HISTORY

5.1 The site and the adjoining industrial sites were granted approval under PA 98/01395/B for Industrial site layout of roads, plots and sewers, Phase II. This application was approved by the planning committee in November 1998. - 6.0 REPRESENTATION Copies of representations received can be viewed on the government's website. This report contains summaries only.

6.1 DOI Highways Division have made the following comments on the application (3 October 2024):

• 1. The amended plans have provided a revised access arrangement to accommodate the Highways request from the previous Highways response.
• 2. The fence line boundary of the storage yard has been moved back from the edge of highway in order to afford entering vehicles space to pull in off the carriageway whilst waiting for the gates to open. This also provides added benefit to the visibility achievable from the exit. The boundary relocation has resulted in the removal of four parking spaces from the proposal.
• 3. The previous Highways response further explored the parking assessment for the application. To summarise, the data provided expected a peak vehicle access of 15 in one 24hr period, with a simultaneous parking demand of 6 vehicle spaces. The reduction in spaces to 12 would still be able to easily accommodate the expected peak use.
• 4. The proposal raises no significant road safety or highway network efficiency issues. Accordingly, Highway Services Development Control raises no objection to the proposal subject to all access arrangements to accord to Drawing No.102 Rev A.

6.2 DOI FRM have stated that they do not object to the application subject to the conditioning the comments relating to Flood Risk in the Applicants email dated 1/7/2024.

• 6.2.1 The applicants had made the following comments regarding flood risk in their correspondence with DOI FRM dated 1/7/2024: "The carpark is to be formed from permeable Hardscaping and to maintain free draining. The container units themselves once installed have a finished floor level of approximately 150mm above ground level, any electrics associated with the development will have termination boxes 1m above ground level, and the containers themselves are watertight."

6.3 Douglas Borough Council does not object to the proposals subject to the following:

• 1. The applicant demonstrates that the Japanese Knotweed contamination can be appropriately treated and removed from the site prior to any construction work taking place to the satisfaction of the DEFA Biodiversity officer.
• 2. That the applicant complies with the Manual for Manx Roads and makes the necessary changes to the position of the entrance gates, moving these back to a minimum of 5m to the satisfaction of the Highways Services officer.
• 3. That the applicant provides details on their flood risk management strategy

• 4. That any lighting installed, should be where possible, low-level lighting to the satisfaction of the DEFA Biodiversity officer so as not to have a detrimental effect on wildlife in close proximity to the site.
• 5. That the applicant consults with the DEFA Forestry Division in relation to any tree root protection that may be required prior to the start of any building works.
• 6.4 DEFA Ecosystem Policy Team have made the following comments on the application (3 October 2024):

• 1. They have no objection subject to conditions regarding external lighting and bird and bat boxes.
• 2. They provide an advisory regarding Japanese knotweed, or any other plant listed on Schedule 8 Part II of the Wildlife Act 1990.

6.5 DEFA Fisheries have no objections to this development from a fisheries perspective, provided that there is no adverse effect on the adjacent watercourse. They note that as the proposed works are in close proximity to the watercourse, precautions will be needed to reduce the possibility of harmful materials such as concrete or washings entering the river (29 July 2024). - 6.6 No comments have been received from neighbouring properties.

- 7.0 ASSESSMENT

7.1 The main issues to consider with the current application are:

• a. the principle of the proposal (SP6, 7 & BP1);
• b. visual impact/impact on the wider environment (EP 22 and GP2 b, c & f);
• c. impact on the neighbouring amenity (GP2g & EP 22);
• d. impact on the highways & parking (TP7, GP2 h & i, SP10); and
• e. Impacts on Biodiversity (EP 4 and GP2).

7.2 Principle of the Development

• 7.2.1 The site is designated for industrial purposes so the principle of developing the storage facility here would be in keeping with the zoning of the area and the general use of the sites and buildings within the estate. In addition, the proposed scheme would also align with Strategic Policy 6 which takes into account the need for employment generating developments to be sited on land for which they are zoned for (as identified on the Area Plans); a condition which the development would comply with given that the site is zoned for industrial use. As the proposal would potentially offer employment opportunities to this area, this aspect would further be compliant through Business Policy 1.
• 7.2.2 The sites proximity to a major employment area on east of the Island, and within Douglas, where there would be easy access to labour, with the location also benefiting from an integrated transport network would further ensure the use is in accordance with SP6.
• 7.2.3 The scheme would also facilitate the optimization of an unused land in an area zoned for industrial use, and for a purpose that is not in conflict with the sites zoning, thus complying with the provisions of Strategic Policy 1 which seeks to encourage development to make best use of resources.
• 7.2.4 Based on the foregoing, it is considered that the principle of the proposed development on this site would be acceptable.

7.3 Visual Impact/impact on the wider environment

• 7.3.1 In terms of visual impacts of the development on the site and surrounding area, it is noted that the proposed development would feature a unique form of development as it does not propose a permanent building but a series of shipping containers linked together and stacked two high with interlinking walkways serving each container, a feature that is not

• common within the estate. However, the height of these would be no taller than the eaves level of the adjacent building to the north of the site, which would be set about 650mm taller than the top of the proposed structure. The appearance of the finish of the containers in crinkled profile, similar to that of the industrial type cladding evidenced on some of the existing buildings within the estate would also serve to ensure that the appearance does not contrast sharply with the character of the area.
• 7.3.2 Further to the above, the perimeter of the site would be enclosed in palisade fencing similar to the adjoining site, which would serve to provide the continuity in terms of roadside finish for the sites within the estate and this weighs in favour of the proposal.
• 7.3.3 On balance, whilst the appearance would be different to the surrounding buildings, containers and industrial sites are intrinsically linked by their uses and the appearance and proposed use would not be seen as an incongruous feature on the industrial landscape. Therefore, it is considered that the proposal would be appropriate for the setting of the area, and would not adversely affect the character of the overall site, and read in accordance with GP2 (b & c) and EP42. A condition would, however, be attached to ensure that the colour of the fencing of the site is in keeping with the general appearance of the immediate street scene.
• 7.4 Impact on adjacent properties

• 7.4.1 With regard to impact on nearby properties, it is considered that the key cconcern here lies in the potential impacts from the activity on site. However, the proposal and its use for storage would not be considered to have any adverse impact on the use of the neighbouring building uses and would be served with its own access of the internal link road.
• 7.4.2 Similarly, the nature of the proposal is envisaged to be low key in terms of visitor volumes, such that it would not have a detrimental impact on the existing businesses on the estate, who are still expected to have higher visitor number, given the volume of vehicular visits usually associated with self-storage facilities of this size, which in most cases amounts to an average visit of 13.1 vehicles per day. Thus, the proposal would be seen as being compatible with the other uses of the industrial type buildings and would be in compliance with GP2g and EP 22.

7.5 Impact on the Highways and Access

• 7.5.1 In assessing the parking requirements for the proposal, it is noted that the scheme provides 12 parking spaces to serve the facility, which would result in a shortfall of 3 parking spaces should the Strategic Plan requirement of 1 space per 100 square metres gross floor space be applied.
• 7.5.2 The scheme would also fail to align with the UK self-storage parking guidance which stipulates that self-storage facilities providing for 100 to 299 units on site would require 13.1 parking spaces, meaning that there would be a shortfall of 1 parking space in this case.
• 7.5.3 Notwithstanding the above, the advice from DOI Highways confirms acceptability of the proposal, as they consider that the reduction in spaces to 12 would still be able to easily accommodate the expected peak use, given that data provided suggests that a peak vehicle access of 15 in one 24hr period is expected, with a simultaneous parking demand of 6 vehicle spaces, meaning that the parking provision would be more than sufficient. As such, it is considered that the parking elements of the scheme would be acceptable.
• 7.5.4 In terms of potential impacts on the adjacent highway, it is considered that the proposal would provide an access that would not impede the access and exit by vehicles from the site, or result in tailing traffic being pushed unto the adjacent highway. As such, it is considered that this element of the proposal aligns with the principles of TP 4.

- 7.6 IMPACT ON BIODIVERSITY (EP 4, GP 2)

• 7.6.1 In terms of the ecological impacts of the proposed development, the application is supported by supporting ecological information, which has been reviewed and accepted by the DEFA Ecosystems Officer and in this respect it is felt that the application has satisfied the principles of Environment Policy 4. Conditions would, however, be imposed to ensure that the required mitigation measures are implemented.

7.7 FLOOD CONCERNS (EP 10, EP 13 & GP 2)

• 7.7.1 In terms of flood risks associated with the development, it is noted that the site is within an area associated with surface water flood risks. However, the applicants have provided details of flood mitigation measures which have been accepted by DOI FRM who asked that these be conditioned on approval. As such, it is considered that the proposal satisfies part of Environment Policy 10. Albeit, a condition would be attached to ensure that the scheme is implemented according to the recommended flood mitigation measures provided in the Applicants Correspondence dated 1/7/2024.
• 8.0 CONCLUSION

8.1 For the above reasons, it is concluded that the planning application would be appropriate for the character of the site and area, and accords with the aforementioned planning policies of the Isle of Man Strategic Plan 2016. - 9.0 INTERESTED PERSON STATUS

9.1 By virtue of the Town and Country Planning (Development Procedure) Order 2019, the following persons are automatically interested persons:

• (a) the applicant (including an agent acting on their behalf);
• (b) any Government Department that has made written representations that the Department considers material;
• (c) the Highways Division of the Department of Infrastructure;
• (d) Manx National Heritage where it has made written representations that the Department considers material;
• (e) Manx Utilities where it has made written representations that the Department considers material;
• (f) the local authority in whose district the land the subject of the application is situated; and
• (g) a local authority adjoining the authority referred to in paragraph (f) where that adjoining authority has made written representations that the Department considers material.

9.2 The decision maker must determine:

• o whether any other comments from Government Departments (other than the Department
• of Infrastructure Highway Services Division) are material; and o whether there are other persons to those listed above who should be given Interested Person Status

9.3 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 Interested Person Status. _____________________________________________________________________

I can confirm that this decision has been made by a Principal Planner 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: 15.10.2024

Determining Officer Signed : J SINGLETON Jason Singleton

Principal Planner

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