Isle of Man Draft Strategic Plan 2001

Submission of the Conservation and Amenity Societies

 

Introduction

These comments represent the common position of a large number (we believe the majority) of the conservation and environmental bodies on the Island. They have been endorsed by: (put list)

on the basis of the following statement,

"These comments deal with the whole of the draft Strategic Plan, which goes beyond the remit of many of the participating bodies. In endorsing these comments, each body is therefore indicating its formal agreement only in those areas where it has specific competence. At the same time, however, each endorses the whole of these comments in general terms, and also acknowledges the remits of other participating bodies in areas where they have particular knowledge or expertise".

We greatly welcome the long overdue publication of a draft all-Island Strategic Plan. We are greatly encouraged by the positive tone of the draft, and the fact that inevitably we have some negative comments on it should it not be seen as implying a general tone of criticism.

We believe that planning policy has moved on markedly over recent years and are encouraged that Government bodies are now committed to policies which are in some cases more advanced than those in the United Kingdom, and which many of our organisations have been advocating for years. We think of the commitment by the Manx Electricity Authority to renewable energy, and the excellent Policy and Guidance Notes for the Conservation of the Historic Built Environment of the Isle of Man produced by the Department of Local Government and the Environment.

However, we do think that the wording of significant parts of the draft Strategic Plan needs tightening up, and we have made detailed comments on most sections of it.

The most important omission is one which may not be easy to put in planning terms, but which follows very logically from the powerful introductory paragraph 1.1.1. Strategic planning must never forget that the Island is indeed the home to the Manx nation, and the preservation of that nation’s culture (in the very widest sense) must be an important aim of policy.

What does this mean in planning terms? It means that the population of the Island must not be allowed to increase too greatly by non-Manx immigration, so as to swamp the native population. It means that there must be a good social mix in all areas of housing, to avoid ghettos, which can also all too easily resolve themselves into one ghetto of the (poorer) native population and another of the (more prosperous) incomers who make no attempt to integrate. It means the recognition that culture is not just a question of the arts or language, but a question of an attitude of shared history and experiences, of the same mindset, everything (in short) which creates a people and a sense of community. In considering every planning application, the Planning Committee should have at the back of its mind what it might not be too fanciful to call a Cultural Impact Assessment, "Will this particular application materially harm the unique character of the Island and its people?"

In times when all too often work and leisure are based around a computer or television screen, a sense of community becomes ever more important. The chairman of one of our participating organisations expressed it as a need to preserve "the good old family spirit". We forget that at our peril.

We feel that one problem which arises is one which those compiling the Strategic Plan cannot solve, and that is that the phrase used in the Town and Country Planning Act 1999 for the Strategic Plan and the Area Plans is "the Development Plan". The overfrequent use of the word development is harmful because it can imply a presumption in favour of development, rather than putting the burden of proof on the applicant for planning approval to show that what he is proposing is at the very least harmless, and at the best, beneficial.

We think it important that the Strategic Plan should be drawn up with the benefit of as much information as possible. We hope that in future it can be co-ordinated with the census, so that perhaps the next revision is not in ten years time but in eleven years, so as to have to hand the information from the 2011 census. We also believe, both now and in future revisions, that there should be a proper Quality of Life Survey done first. These are now commonly carried out by local authorities in England.

While the plan is intended to last ten years or so, it does need to take a longer view of some areas as well. This is especially true in considering the different sectors of the economy. Most of the Island’s wealth is now generated by the Finance Sector, but the plan must remember that both agriculture and tourism remain important in the long term, and they are sectors of the economy where a long view has to be taken. If good agricultural land is lost, it is likely to be lost forever. This is totally different from the effect of rejecting a planning application for an office, which can be brought back again in the future or sited elsewhere. Similarly, tourism on the Island depends upon the continued attractiveness of the landscape and the townscape, and if these are seriously compromised, the future of tourism will be jeopardised. We consider economic diversification to be very important. The Island has to consider what will happen if anything goes wrong with the Finance Sector, whether through tax harmonisation or any other reasons.

The organisations which have joined in endorsing these comments hope to be able to work with the Department as the Strategic Plan process continues. We are encouraged by the positive tone of the draft, and hope that our comments will be taken in the same spirit.

Chapter 2 Strategic Aim

    1. We do not think that it is right to include the results of an annual policy review
    2. in a Strategic Plan which is intended to last 10 years. The whole of section 2.1 should be deleted and replaced with , "The Strategic Plan should be consistent with the policy of Tynwald".

    3. We share the hope that planning in practice can help to achieve these admirable aims.

Chapter 3 Strategic Objectives

    1. Resources should be defined. It should be noted that it includes our built and natural heritages
    2. 3.2 (d) All words after "resources" should be deleted

      Add 3.2 (g) "To encourage the energy-efficient design of housing to make the best use of energy"

    3. (a) This is not actually an objective as worded; Add at the beginning, "To support the precautionary principle which assumes…………"
    4. 3.3 ( c ) This should not be interpreted as encouraging development per se. High quality is a somewhat meaningless phrase without definition. Perhaps reword, "Any development anywhere in the Island should be of the highest quality of design ."

      3.3 (f) Urban regeneration must not be used as an excuse for the wholesale destruction of usable houses. There should also be reference to rural regeneration by encouraging agriculture.

      3.3 (i) This should refer also to surrounding seas.

    5. This should more logically be headed, "Transport, Settlement Patterns and Communications".

Add 3.7 Manx Identity

"To promote the preservation of the Manx identity and of the community spirit which has traditionally prevailed in the Island".

 

 

 

Chapter 4 Strategic Policies.

There needs to be some thought as to the relationship on the one hand between the Strategic Aim/Objectives and the Strategic Policies, and on the other hand between Strategic Policies and Detailed Policies. We note that strategic objectives and policies share the same heading which are not carried through into the detailed policies. We wonder exactly why certain matters have been selected as strategic policies. We are almost tempted to wonder whether Chapter 4 could be omitted altogether, and one could go straight on from the strategic aim and allowing to objectives to the detailed policies.

We think on reflection, however, that it may be useful to set out some strategic policies. We would not, however, share the choice made by the authors of the draft. We would suggest that there are 11 points of overriding importance which should be designated as strategic policies. These are the points which, between them, the organisations endorsing these comments believed to be the most important planning issues facing the Island. They are (in no particular order) as follows:

Strategic Policy 1

All planning policy should be consistent with sustainable development. Sustainable development means development which is socially, ecologically and economically beneficial, now and in the long term. (Please see the Epilogue to these comments for a more detailed explanation of the concept, which is now central to much United Kingdom and European Union policymaking in this area ).

Strategic Policy 2

The planning process should do all it can to encourage the introduction of an all-Island fully integrated transport system

Strategic Policy 3

The landscape and the countryside should be protected from inappropriate development and from pollution

Strategic Policy 4

The quality of the built environment should be maintained and enhanced

Strategic Policy 5

Planning policy should promote rigorous waste recycling targets.

Strategic Policy 6

Planning policy should promote the use of renewable energy.

Strategic Policy 7

Planning policy should promote the continued existence and viability of agriculture.

Strategic Policy 8

Economic development should be managed and contained in order to preserve the character of the Island.

Strategic Policy 9

Development should not in any way diminish the quality of life of the people of the Island. Quality of life should be the correct measure, not standard of living, and this should be based upon proper Quality of Life Surveys.

Strategic Policy 10

Local participatory appraisals and the views of amenity societies should be given weight in coming to planning decisions.

Strategic Policy 11

There should be necessary provision for affordable housing, and to make sure that an adequate proportion of the housing stock is affordable and that a further adequate proportion is within the public sector or owned by housing associations or building co-operatives.

 

 

  1. General Development Considerations

    1. General Policy 2 (d), add "or landscape features"
    2. In General Policy 3 c : after conversion, add "with great sensitivity"

In (d) add "with safeguards for traditional buildings"

We believe that (g) should be more explicit as to what is meant by this expression, which could be a substantial loophole for almost anything. We would suggest rewording as, "developments which have been held by a Public Inquiry to be of national strategic need".

5.5.2 We think it is essential that adequate resources and commitment are put into enforcement. At present there appears to be a lack both of staff and determination. Without enforcement, the whole planning system becomes worthless.

    1. Public Art

General Policy 9 is an excellent one. It should, however, be emphasised that public art should be of the highest quality. The two examples cited in 5.7.2 are not universally acclaimed. The Isle of Man Arts Council has been successful in commissioning two pieces of sculpture of international standard, one already in place at the Erin Arts Centre. The other, for the Promenade in Douglas, will be unveiled in 2002. It is work of this quality which is needed, although it is expensive. There is now a society called Manx Public Art which is intent on supporting just such enterprise. There is legislation in England to encourage public art on major buildings, and the absence of realistic provision for art at the new hospital shows a major lack of understanding of the needs (particularly financial) of providing such an environment.

We would therefore suggest that General Policy 9 should read, "In major development proposals, there should be included provision for artwork of the highest possible quality which is of value to public amenity".

 

    1. The Natural Environment

We felt that this was a positive section of the Draft and one with which we were generally in agreement. The only caveats we had were as follows:

    1. We believe that this section does not give sufficient encouragement to market gardening which has a valuable role to play in providing fresh food for the Island and in keeping agricultural land in productive use. We would suggest that the policy should be to adopt the fifteen criteria for sustainable development called "Defining Rural Sustainability", as had been adopted in Scotland under [Alice to provide]

      1. The expression "inappropriate development" at the end of the first paragraph needs to be defined, with appropriate guidelines. We were a little concerned that the third paragraph of 6.1.2 and policy 1 could provide a loophole to allow undesirable development. If the wording of Environment Policy 1 is to stay the same, we would suggest that there should be added at the end "but it must be sympathetic to the local area and have the minimum possible impact."

      1. We felt that the expression at the end, "in the wider countryside as well" was perhaps unduly restrictive and we would prefer, "but also Island-wide".

      1. Again "inappropriate development" needs definition, with guidelines.
      2.  

      3. The Manx Nature Conservation Trust is now the Manx Wildlife Trust.
      4. We would suggest that even if the Manx Government does not sign up to the 1992 European Union Habitats Directive, it should consider designating Special Areas of Conservation (SACs) as suggested by the Manx Wildlife Trust. We also hope that marine nature reserves can be designated, especially around the Calf of Man.

      5. We would like this to go further and to give positive encouragement to the planting of mixed broadleaved deciduous woodland, especially of native genetic origin, where appropriate.
      6. We think it is dangerous to use the English system of classification for agricultural land. A separate Manx system should be used, to protect what is the best agricultural land in the Island, even if it would not be of the highest grade in England. In the reference to appropriate tree and shrub planting on the sixth line of the first paragraph, we would prefer a reference to the appropriate planting of native trees and shrubs, preferably of native genetic origin.

6.1.14 In general terms we would prefer to see soft coastal protection, through the encouragement of dunes, rather than hard structures which can cause problems further down the coast.

6.1.15 We would prefer Environment Policy 20 to be that all coastal development should be subject to an environmental impact assessment.

      1. We would especially commend Environment Policy 22 with which we would strongly agree.

We were concerned, however, to see no reference to incorporating the specific designation of Areas of Scenic Significance or High Landscape Value in a map issued in conjunction with the Strategic Plan . The reference to these in section 6.1.5 is of little use if they are not defined. They should be fixed once and for all as areas where there would be an effective prohibition on development. The map could also show other matters which need considering on an all-Island basis across area plan boundaries, for example flood plains . It might in addition be useful to show different categories of agricultural land, according to a purely Manx classification.

 

6.2 The Built Environment

We felt that this was an excellent section which we would strongly endorse. We hope, however, that specific reference could be put in to the outstanding document produced by the Department of Local Government and the Environment, "Policy and Guidance Notes for the Conservation of the Historic Environment of the Isle of Man." Our only comments are:

6.2.2/3/4 We think that stress should be put on the need for a properly-funded grant system to work in conjunction with the legislation, and for there to be quick and effective enforcement of any breaches. Resources need to be provided to expedite the registration of the many buildings which should be registered but are not. There also needs to be the political will and courage to register buildings in immediate danger and others which commercial interests might prefer to remain unregistered.

We would like to see here some reference to the need to protect

and preserve the Islands many miles of stone walls or hedges

which can all too easily be demolished or fall into disrepair.

      1. We would suggest that the first sentence be replaced with, "Every historic settlement in the Island had its own individual character and identity. If this has survived, it needs to be conserved and enhanced, but if it has not survived, no attempt should be made to preserve an identity characterised by low quality twentieth century development, and good design should be the principal criterion for any new buildings in such an area."
      2. We think it important that the expression "regeneration" should not be used as a cover for the wholesale demolition of usable housing.

 

    1. Environmental Protection

We support the environment policies set out in this section. We would, however, like consideration to be given to strengthening Environment Policy 39 to read, "Development which is likely to have any significant impact on the environment will be required to be accompanied by an Environmental Impact Assessment. Without prejudice to the generality of the foregoing a development will be deemed to have significant impact on the environment if it is on a sensitive site or if it is a housing development which either (a) is of 10 or more units or (b) would if built consist of more than one per cent of the housing units in the settlement in which it is situated"

 

 

 

  1. Housing

For the purposes of these comments, we have accepted the Department’s population projections contained in section 7.4.

7.1 We think it important to stress that housing policy must relate not to the private

sector alone, and we would suggest that the words "in both the public and private sector" should be added after the word "available".

7.2 We would accept the historical summary in this section.

    1. We accept sections 7.3.1 and 7.3.2, but between them we think that another paragraph should be added:

"7.3.1a Different types of private housing (private, local authority and housing association) should be mixed together in the same areas and not separated in ghettos. Incorporation of an element of public housing in any new areas of housing could allow some existing public sector housing to be sold off, thus improving the social mix on estates and giving residents a stake, actual or potential, in where they live".

We would not support the selling of public sector housing unless at least an equivalent number of public sector dwellings is built, but good planning should lead to mixed communities and not to the ghettos we have at the moment, such as on the one hand housing estates such as Pulrose, Willaston, Janet’s Corner etc. and on the other estates of "executive homes" on the outskirts of Douglas and other towns.

      1. We found Housing Policy 1 confusing. We accept sub-paragraph (a), but with a rider "but so as to preserve necessary green spaces within the settlement". We did not follow the differentiation between (b) and (c), which seems to give excessive weight to arbitrary questions of when a particular area plan has been revised. We would suggest that the two sub-paragraphs could be replaced by a new sub-paragraph (b) "by the development of land zoned for development under any Area Plan for the time being in force".

      1. We applaud the reference to sustainable urban extensions in Housing Policy 2, but feel that it would benefit from clarification by adding after urban the words "(but not suburban)". Extensions need to have a traditional, urban or village feel, rather than the suburban sprawl which has been seen all too readily over the last 30 years.

      1. We disagree strongly with the purely arithmetical approach contained in this section. Reasons for the location of new housing need to be strategic not historic. We would rewrite the proposal to read, "In determining the proportion of the total increase of housing which should be accommodated in each settlement or in each area of the Island, the Department should have regard to the availability of sites which meet the requirements of this Strategic Plan, and in particular to the infrastructure and to the availability of employment near any proposed sites."

    1. Affordable housing is one of the most pressing issues facing the Island at present. It is meaningless unless properly defined. By whom is the housing to be affordable – single people in manual jobs, single people in office jobs, or couples both in well-paid office jobs? We think that much more thought needs to be given to this section, as the preparation of the Strategic Plan unfolds. The needs of key workers (in education, health and other services) should not be forgotten by Government.

Encouragement should be given to self-build schemes, housing co-operatives and housing associations. (Guidance on housing co-operatives could be obtained from those promoting Manx housing co-operatives who have done significant work in this area).

Affordable housing should mean not just housing the purchase of which is affordable. The private and public rented sectors also have a rôle in providing affordable housing. Rent control could be considered for the private sector, but it is important that this does not lead to landlords’ not having the means to repair their properties properly.

7.8(c) We strongly believe that this provision should be strengthened. There is a need for greater controls of detailed design and materials, notably as to paint and finish, so the results do genuinely blend in unlike recent attempts where the overall effect is too harsh and unnatural.

7.9.3(c) We do not support the discouragement given to market gardening by this provision. We believe that market gardening should be encouraged in order to provide fresh produce for the Island and to utilise agricultural land productively.

7.9.3 (d) Whilst we accept that there can be abuses, part-time farming may be the only way to retain land in agricultural use and should not be discouraged. The realities of the present economic condition of agriculture must always be kept in mind.

      1. We feel that the penultimate sentence of housing Policy 10 is unduly restrictive.

In more general terms we believe that the very sensitive conversion of genuinely-redundant traditional agricultural buildings into residential accommodation, either for the farmer’s family , for letting or for tourist use, could provide useful extra income for struggling farmers. In many cases, to avoid abuses, planning conditions should be imposed requiring ownership to be retained by the farmer and for the approved use to last only so long as at least one dwelling on the holding is occupied by someone primarily engaged in agriculture. The Government might be able to fund an independent trust which could deal both with sensitive conversion and the administration of letting if outside the family.

      1. We disagree with Housing Policy 11. We believe that very sensitive exact restoration of tholtans should be allowed, as this will keep the countryside alive, will preserve old buildings and could provide substantial extra housing. (When considering restoration proposals, the most important point is that the tholtans are not painted white but remain with natural stone exposed or coated with a simple uncoloured render, so that they are not obtrusive in the countryside). A possible way forward would be for the government to fund a trust on the lines of the Landmark Trust which would have the expertise to deal with sensitive restoration, although we would suggest that such houses should be for permanent occupation, not for holidays like those restored by the Landmark Trust.

      1. We would point out that it is difficult for such conversions to be viable unless mortgage lenders can be persuaded to reverse their present policy of not lending on flat conversions.

One very important factor which was left out of Chapter 7 was the question of whether zoning should be for purely residential use or for mixed use. We feel that some areas should be zoned for mixed use, so places of employment can be near where workers live. Clearly excessively noisy or polluting workplaces could not be allowed in such a zone, but the replication of traditional settlements, which do have a mixture of houses, shops and places of work, is desirable on social, environmental and aesthetic grounds.

In addition, we would also suggest that some housing could be erected on unused land on some of the trading estates (for example Ronaldsway Trading Estate) which could include innovative modern design which would not fit in to a traditional settlement. Such a setting might also be suitable for self-build houses.

We would also like to see reference to the need for planning control to go hand in hand with properly enforced building control to ensure that aspirations in planning terms as to quality of design and construction are in fact put into effect

 

8. Business

    1. We feel that the most difficult aspect of this laudable aim is to diversify employment, so as to reduce reliance on one particular sector (at present clearly the finance sector) in an Island with virtually no unemployment, without at the same time leading to substantial immigration to fill the new jobs. Somehow the policy has to move existing residents from jobs in a sector on which there is too great an emphasis, to new jobs in more diversified sectors. It is a challenge to which we do not think there is any easy answer.
    2. Industry and Storage and Distribution.

      1. We note that there is no mention here of the railway. Location of facilities requiring the transport of large loads near the railway would reduce the need for articulated lorries on the Island’s roads, for which they are totally unsuitable.

      1. We would support Business Policy 4, and believe that it is important that it should be enforced fully which has not always been the case hitherto.

8.3.4.(b) and Business Policy 5 (b)

We think that there should be more definition of what buildings are being referred to here. We wonder in fact how many such buildings are actually unsuited to any but office use.

We believe that Business Policy 5 in fact needs substantial expansion. Dispersing offices throughout the Island, if practical, could ease problems of commuting and provide employment other than purely in Douglas and Castletown.

We think it is vitally important that town centres remain alive and do not become dead at nights and weekends, which can happen if all the buildings are converted to office use. We would therefore oppose any policy which led to the conversion of residential, or potentially residential, properties in town centres to office use, certainly on such a scale as to include the majority of properties there. Similarly, the vitality of shopping centres must not be compromised by viable shop units being converted into offices. Much useful work has been done in England on the Living Over The Shop (LOTS) initiatives, and we would like to see that commended here. We would therefore suggest that a new Business Policy should be added, perhaps worded, "On any application for conversion of a building in a town or village centre to office use, first consideration should be given to the need to preserve each town and village centre primarily for residential and retail use, and so as to ensure that a majority of buildings in the town or village centre are not used as offices."

8.4 Retail

.We support Business Policies 7 and 8. We believe it is important to retain small village shops and post offices, and we would like to see a policy hostile to their conversion to other uses.

It is very important that the space above shops remains in use. It keeps a town or village centre alive at all times of the day and night, and uses up useful space which would otherwise be empty. We would refer to the Empty Property Initiative. One problem which often sterilises the space above shops is the insertion of a modern shopfront which does not allow separate access to the space above the shop. We would therefore suggest that there should be a Business Policy, "On any application for a new or altered shopfront, there must be provision for separate external access to the floors above the shop." If the space above a shop is no longer needed to accommodate the shopkeeper and is not being used for the storage of goods, its conversion, preferably to residential use, should be encouraged. In general terms we believe that there should be a preference for residential as opposed to office user here.

 

    1. Tourism

We support Business Policies 9, 10 and 11 but we do not think that they go far enough and we think there should be more encouragement of suitable tourism. The future for the Manx tourist industry is not the mass market tourism of the past, but rather niche markets. We would identify (and we are sure it is not an exhaustive list)

We think that policies should positively encourage the development of this sort of tourism, and it should be recognised that it may sometimes conflict with what would otherwise be good planning policy. For example hill walkers may need a bothy, which might be a new stone-built structure in the middle of the countryside, which would not get planning approval for any other purpose, but which would be quite acceptable for its own purpose.

It is also important that consideration is given to the fact that the preservation of the appearance of the Island is important if it is to be attractive to tourists. This applies both to the countryside and to the townscape.

We would suggest that Business Policy 11 should have added to it the words "and would be compatible with the preservation of the townscape".

 

  1. Recreation, Open Space, Community Facilities

    1. There should be a clear distinction between public and private open space. Private open space can provide landscape value, but does not provide recreation. Using the distinction between (a) and (b) in 9.2.2, recreational open space must be public open space, but amenity space providing visual and psychological relief within built-up areas can be either public or private. We would support the standards set out in paragraph 9.2.2, which are a clear advance on what is actually happening.
    2. We agree with Open Space Policy 2, but it is important that there is somehow a commitment to the maintenance of the space.

    3. Civic and Community Facilities

When an Area Plan considers the need for civic and community facilities, it should consider not only the area it is covering, but also neighbouring areas if they do not have such facilities, if adequate affordable facilities could be provided in the study area to serve the deprived area. It is clear that at the moment some areas (for instance those which have new schools) have much better community facilities than others.

      1. Neighbourhood Centres.
      2. We feel that the words "where relevant and appropriate" in Community Policy 1 could be misleading. It might be best to state the exact circumstances in which such provision would be neither relevant nor appropriate (presumably only if there was already suitable provision nearby or if the scale of development was not large enough).

        It may also be useful to give a definition of neighbourhood centres. We are not entirely happy with the emphasis in the second paragraph of 9.3.2. We think that the community centre/meeting place is very important, possibly more important than some of the other facilities mentioned such as the hairdressers.

      3. Community Centres

It is important that these facilities are affordable to encourage use

9.3.4 Hospitals

If the requirements of the new hospital are to be dealt with in the Braddan Area Plan rather than the Strategic Plan, the Department will need to ensure before the Strategic Plan is finalised that the Braddan Area Plan does actually do this. We understand that the Department of Health and Social Security has not made any appropriate submissions so far in the Braddan Plan process. The difficulties of access to the new hospital during the TT are clearly all-Island strategic ones rather than purely ones relating to Braddan.

 

9.3.5 School Sites

This again is an area where an all-Island policy is needed. School catchment areas (which it must be remembered in the Island are very informal) can straddle the boundaries of areas covered by area plans. Certainly the areas covered by the secondary schools are covered by more than one area plan. It would seem, therefore, logical that the provision certainly for secondary schools should be dealt with in the Strategic Plan. We would suggest that the Department should invite the representations of the Department of Education on this point.

We agree with the Proposal and also with Community Policy 3, although we would comment in passing that it does seem that some estimates in recent years of the sizes of new schools have been far too conservative.

9.3.6 Community Health Care Facilities

We feel that Community Policy 4 puts undue obstacles in the way of new community healthcare facilities. Sheltered housing, for example, is a very neighbourly land use. Good examples are Magher Vay at St.John’s and the Millhope complex in Castletown, which should be examples for other areas.

9.3.7 Prison Service

The Association of Braddan Residents makes the point that Tynwald itself has not yet endorsed the principle of erecting a new prison on a greenfield site.

9.3.8 Fire Service

We agree with Community Policies 6, 7 and 8

 

There were three important areas which were not covered by Chapter 9 of the plan.

The first is the Police Force. We regret the absence of the section included in the Consultation Draft which we endorse. Planning policy should support the continued presence of the Police in the community, and an extension to the number of police houses which is the best way of ensuring community policing.

 

The second area not properly covered was national sports facilities. Such a section should be inserted, after consideration of the recommendations of the report shortly, we understand, to be made to the Department of Tourism by outside consultants. There should also be consultation with the Sports Council. Sports facilities should be spread throughout the Island and not concentrated too much in any one area. The provision of adequate sports facilities should be encouraged in established areas as well as in new residential areas.

 

The third is any question of burial grounds. With the increasing interest in woodland burial grounds, there should be a policy. We would suggest that this policy should be, "Extensions to existing parish burial grounds will be supported but woodland burial grounds will also be approved in areas where woodland already exists or would be appropriate".

 

  1. Transport and Infrastructure

We feel that chapter 10 is one of the most important in the Draft. Much of it is unobjectionable but it does not go far enough. We believe that sections 10.5, 10.6, 10.7 and 10.8 could remain as they are. We think that the earlier sections should emphasise that the highest priority is the introduction of a proper integrated transport system. Buses, trains, the electric railway, the Manx boats and the airlines should all have co-ordinated timetables. Planning must therefore encourage integration and encourage easy connection between the various modes of transport. It might assist if all public transport came under the Department of Transport not the Department of Tourism.

Buses are the transport priority for the immediate future. We believe that if they were made free and ran more frequently, every quarter of an hour at rush hours, for example, the Government could encourage much more widespread use. This should lead on to a new policy, "Everything possible should be done in planning terms to ensure a widespread, efficient, free and accessible bus network."

Efficient feeder bus services using small buses should be introduced and integrated into the main transport system. This has planning relevance in that this could provide good infrastructure for areas which would not justify a main bus service.

There should be a further policy to encourage bus lanes where possible.

Modern trains should be introduced to the Isle of Man Railway (while keeping the existing trains for tourist use) and modern rolling stock onto the Manx Electric Railway. The two systems should be linked by an efficient modern tramway along the Promenade walkway near the new cycle lane, and this should run from the Electric Railway station at Derby Castle the whole way to the Isle of Man Railway station at Banks’ Circus. The proposed pedestrianisation of the North Quay would considerably assist with this. There should therefore be a policy to promote the linking of the two railway systems. We think the suggestion that the railway track from Douglas to Port Erin should be out of action for some years owing to the laying of pipes beneath it extremely unfortunate.

Consideration should then be given to restoring the railway link from Douglas to Peel and perhaps to Foxdale and Ramsey. There should be a policy to encourage the reopening of disused railway routes and not to allow any planning applications which might compromise this objection.

Separate consideration should be given to school transport. Supervised walk-to-school parties should be encouraged and school buses should be put on as a separate service which does not inhibit bus use by the public during the morning rush hour. We understand the present policy of the Department of Education is to construct car parks at all new schools because of the volume of children being brought to school by cars. We believe that this is the wrong way round - more car parks mean more cars - and that there should be an active policy to discourage children being brought to schools by cars.

Cycling should be encouraged and there should be a policy to encourage cycle lanes. Consideration should be given to designating the Douglas to Peel railway line (most of which is now a footpath) as a cycle lane pending the relaying of the railway track.

The existing draft of chapter 10 appears to ignore the most important form of transport, on foot. Walking must be seen as a positive means of transport, not purely as something recreational or for short distances in areas of housing. There should be a policy that all road layout should respect the needs of those walking as a means of transport and indeed encourage such pedestrian use. There should also be a policy of constructing pavements on busy main roads which at present have none.

Parking is a significant problem in the Isle of Man. There are three types of parking, for residents, for workers (principally office workers) and for shoppers. Parking for residents is considered in the housing chapter of the draft plan. Short stay parking for shoppers should be encouraged so as to ensure the viability of town centres, although ideally as many as possible should come by public transport. There should be a policy that adequate short-stay parking should be available in town centres. There is no reason why zoning should not differentiate between long-stay parking and short-stay parking.

Park and Ride schemes could be useful in removing traffic from town centres by allowing those who do not live on a bus route to use public transport for the last and most congested part of their journey, but they must be fully integrated into the transport system and be sited so as to allow easy access from out of town without having to go through particularly busy areas.

Long-term parking by commuters should be aggressively discouraged. Publicity and subsidy should instead encourage the use of public transport . The more parking is provided, the more cars will come into the towns. First of all the public transport system needs to be made adequate, and then the amount of long-stay car parking needs not to be increased but in fact to be decreased. With a proper public transport system , there would be no need for any requirement for parking as a condition before planning approval is given for office development. There should therefore be a policy that once an adequate integrated public transport system is in place, planning should discourage long-stay car parking.

It is no good giving planning approval for a development and then considering transport implications. Any development of any size should have to be accompanied by a properly thought out Transport Brief.

  1. Minerals, Energy and Waste
    1. We would in general terms accept the summary in this section. We believe, however, that 11.1.5 is unduly restrained and we would prefer to reword it, "There is also continued keen interest to promote naturally sustainable resources of all kinds, and in particular wind. The development of such resources is likely to have local environmental effects. Accordingly, the Department will need to balance positive aspects of using renewable energy resources against any impacts on the local environment. There is a need to conserve energy in the home."

      1. We would suggest that the Planning Committee should liaise with the section of the Department of Local Government and the Environment which formulates policy for waste management. We believe that the policy quoted in 11.1.6 would be improved by the inclusion of targets, as follows

"To develop and promote an integrated waste management plan embracing by target in ten years time –

a Reduction of waste produced by 35%

b Re-use, recovery and recycling of 70% of domestic waste and 90% of industrial waste

c Incineration with energy recovery and

d Landfill

and which recognises the "user pays principle"

      1. We have no comments on this section except to approve the reference to the fact that minerals can be extracted only to meet the needs of the Island, in other words that they could not be quarried for use outside the Island.
      2. Energy Policy 1. A further sentence should be added to this policy at the end, "Such proposals should also be consistent with the targets for renewable energy and climate change the Manx Government has to meet according to the Kyoto Agreement."

We believe that there should then be a specific policy section on Renewable Energy, the reasoned justification of which we believe should be (replacing 11.2.4), "The Isle of Man is lucky to be so-placed to take advantage of the wind, water and the sun. Such abundant energy from these sources will be exploited in the future. Wind turbines and sea current devices are being investigated and considered by the Manx Electricity Authority. Concerns about noise and visual impact will be monitored by the Department. Homes, offices and factories will be encouraged to conserve energy. Grants to insulate homes will continue. The Manx Energy Advice Centre at Silverdale will promote household alternative energy devices to save energy on fuel and the use of hybrid electric cars. Accordingly, Energy Policy 2: Development involving alternative sources of energy supply, including wind and water and tide power, the use of solar panels and the use of hybrid electric cars will be part of the environmental objectives on all the policies set out in this plan".

Waste Policy 1. We would add at the beginning, after civic amenity sites, "composting sites", and we would add a new sub-paragraph(h) "the heat is generated/used in the most efficient manner (see the energy section of the draft strategic plan)".

 

Appendix 1

We are not persuaded by this appendix. We believe that the Strategic Plan should not preclude the possibility of a new settlement including innovative mixed housing with affordable provision for the young and/or as a centre for ecology and new technology.

 

 

 

 

 

 

Appendix 2 – Guidance on Requirements for the Undertaking of a flood Risk Assessment.

We would query why the provisions of the United Kingdom Planning Policy Guideline 25 have been varied.

 

 

In conclusion, we hope these comments are helpful. We would be pleased to expand upon any if it would assist the plan process.

 

Epilogue

Sustainable development is now central to United Kingdom and European Union policymaking on planning as well as many other areas, but it is a concept which is not always understood and can be misinterpreted. We therefore thought that it would be useful to explain some of the background to the idea and to expand upon what we have said when formulating our suggested Strategic Policy 1.

The definition which we prefer is that sustainable development is development which is socially, ecologically and economically beneficial, now and in the long-term.

The Town and Country Planning Association has linked it into the planning process thus :

"Planning must look outward for its purpose, towards citizens and their world. Sustainable development provides an explicit new focus on managing change for the better to benefit everyone. Improved, more inclusive processes are needed, to shape change to get us where we want to be, and to provide a toolkit which will enable planners and others to develop strategies and plans into action. Seven actions can be taken which will assist:

1 A duty to promote sustainable development:

For local authorities and other agencies responsible for planning, implementing or investing in public services. infrastructure and development. Putting sustainable development on a par with education, health, transport and other key services.

2 Visions and strategies for sustainable development:

At various levels and generated through collaborative, deliberative processes involving all stakeholders; to identify community needs and opportunities and suggest ways of making things happen. New systems are also needed to monitor progress towards objectives. Are we getting there? If not, what changes do we have to make?

3 Community planning at all levels:

From a spatial sustainable development strategy for the United Kingdom, to neighbourhood action plans and development control, new frameworks and tools are needed to facilitate the making of political choices at various levels in the development process. Democracy and subsidiarity are key tests in this hierarchy, which should emphasise the shift away from the waste of natural resources, to conservation and replenishment.

4 Partnership Trusts:

Independent, but fully accountable organisations involving the public, private and not-for-profit sectors should be created, to bring forward sustainable development in areas where a wide range of parties need to be engaged. Formal mechanisms would be needed to ensure public scrutiny and democratic accountability.

5 Rewards rather than penalties:

To encourage environmentally sustainable development and practices. Too often in planning, the emphasis is on the negative

6 Capturing betterment:

A more transparent system than planning gain, to enable the community to benefit more fully from the uplift in land values created by development planning.

7 Mutual learning for participation:

Education for citizenship and participation for all, to encourage full stakeholder involvement in town and country planning for sustainable development."

Source: TCPA, Your place and mine: Reinventing Planning (TCPA, October 1999), designed as the framework for policy action for the TCPA in the first decade of the new Millennium.

The idea of sustainable development has been defined in many ways, but "the most familiar definition remains that given in the Brundtland Commission report, Our Common Future (1987): ‘development which meets the needs of the present without compromising the ability of future generations to meet their own needs.’ For the United Kingdom Government, in its 1999 sustainable development strategy report, it is about ‘ensuring a better quality of life for everyone, now and for generations to come’; this means meeting four objectives at the same time, at home and around the world:

  1. social progress that meets the needs of everyone;
  2. effective protection of the environment;
  3. prudent use of natural resources;
  4. maintenance of high and stable levels of economic growth and employment.

Another definition, from the Real World member Forum for the Future, sees sustainable development in this way:

‘Sustainable development is a dynamic process which enables all people to realize their potential and improve their quality of life in ways that simultaneously protect and enhance the Earth’s life-support systems.’

The starting point for definitions of sustainable development is the diagnosis of unsustainable trends in the economy, and in our exploitation of natural resources. The core concepts behind the term now have wide acceptance. They are that:

The aim of sustainable development was endorsed by 149 countries, including the United Kingdom, at the UN Earth Summit on environment and development at Rio de Janeiro in 1992. This conference agreed a global action plan for sustainable development – Agenda 21. Nation states and municipalities have since produced many national and local Agenda 21 strategies. In the United Kingdom, all local authorities were to have drawn up a Local Agenda plan by the end of 2000. Since Rio, many international organisations, businesses and other bodies around the world have also endorsed the goals of sustainable development.

Sustainable development is a political process. It requires judgement and trade-offs about what counts as essential environmental ‘capital’ and what does not, and how much of the Earth we are prepared to share with other species. Thus it is full of contested ideas and ethical dilemmas, as well as being concerned with techniques for assessing our environmental impact and evaluating risks and choices in as an objective a way as possible.

(Sources: WCED, Our Common Future, (Oxford: OUP, 1987); Forum for the Future, Understanding Sustainability, (London: Forum for the Future, 2000); DETR, A Better Quality of Life for All, (London: DETR, 1999); UNEP/WWF/IUCN, Caring for the Earth, (London: Earthscan, 1991) )"

This is an extract from p. 29 of the book ‘From Here to Sustainability’, (London: Earthscan, 2001). It is by the Real World Coalition, an alliance of 25 United Kingdom charities and non-governmental organisations, formed in 1995 to co-operate on promoting sustainability, which they see as an essential precursor to solving their separate concerns. Real World members include the Town and Country Planning Association, Christian Aid, Friends of the Earth, Transport 2000, the Wildlife Trusts, WWF-UK and the United Nations Association.

The parallels, however between the demands of Agenda 21 and a Strategic Plan are obvious. We hope that the preparation of this plan can be in accordance with the principles laid down at Rio, with a view to ensuring that as the Island develops over the next ten years, it does so in a genuinely sustainable way. If that can be at the forefront of the thinking of the Department, both in drawing up the plan and in deciding planning applications in the future, it will go a long way towards meeting the aspirations of the various organisations which have endorsed our common position.