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Miss. S. Corlett, Principal Planner, Planning and Building Control Directorate, Department of Environment, Food and Agriculture, Murray House, Mount Havelock, Douglas, Isle of Man, IM1 2SF.
24th May 2019 Our Ref: PW/19037
Dear Sarah,
I refer to planning application 1900373A for approval in principle for the erection of buildings to provide exhibition space, retail accommodation, a tourism / residential facility, residential apartments and restaurant with associated 142 parking spaces at the former Marine Biological Station, Breakwater Road, Port Erin, Isle of Man IM9 6JA.
I have been asked to address as part of this application the issues of affordable housing and open space. The starting point for any consideration of these matters is the statutory approved Plan. In this case it is the Isle of Man Strategic Plan adopted on 16th February 2016. Additionally, the Area Plan for the South predates this coming into operation on 1st March 2013, but clearly this earlier Plan remains relevant, especially in relation to detailed issues; except where it contradicts the later produced Strategic Plan. Both documents form part of Isle of Man Development Plan for the Port Erin area and will be referred to in this letter.
Housing Policy 5 of the Strategic Plan states that:
> "In granting planning permission on land zoned for residential development or in predominantly residential areas the Department will normally require that 25% of provision should be made up of affordable housing. This policy will apply to developments of 8 dwellings or more."
The issue to consider here is whether the site of this application is within land zoned for residential development or in a predominantly residential area. Map 7 of the Area Plan for the South defines the land zoned for residential development. It is clear that the site of this application is not so zoned, being specifically allocated for Mixed Use as Site 22 on page 59 of the Plan. Equally, the site is not within a predominantly residential area being separated by nearly half of a kilometre from the nearest residential area.
It is therefore clear on both strands of Housing Policy 5 that there should be no requirement for affordable housing for this scheme.
Landmark Planning Ltd, 10 Salisbury Road, Leicester, LE1 7QR T: 0116 2856110 E: [email protected]
| No. of Bedrooms | Occupancy Level | Formal Open Space | Children’s Play Space | Amenity Space | Total (sq.m.) |
|---|---|---|---|---|---|
| 1 | 1.5 | 27 | 9 | 12 | 48 |
| 2 | 2 | 36 | 12 | 16 | 64 |
| 3 or more | 3 | 54 | 18 | 24 | 96 |
Open Space standards are outlined in the Strategic Plan for the island. As para. 10.3.3 outlines the relevant objective for this planning application will be to ensure that ‘adequate provision within new development’ is made for sport and recreation opportunities.
Recreational Policy 3 of the plan states that:
> ‘Where appropriate, new development should include the provision of landscaped amenity areas as an integral part of the design. New residential development of ten or more dwellings must make provision for recreational and amenity space in accordance with the standards specified in Appendix 6 to the Plan.’
Table 1 of Appendix 6 sets out a framework for the provision of open space and amenity space for development, although as the Policy acknowledges by the use of the term ‘Where appropriate...’
In this instance it is therefore appropriate to consider the nature of the scheme and what is appropriate to provide for such a development.
The scheme is a mixed use one, which will have a character very different to a typical residential development in an area primarily used for that purpose. In summary the proposals are 14 aprt-hotel suites; 55 residential apartments; restaurant / bar of 490 sq.m; retail 236 sq.m; and, an exhibition space of 205 sq. m. Residential use, although significant, represents only one of 5 uses in the proposed development. And as the accommodation is fully in apartments linked to commercial uses is unlikely to attract many, if any, families with children. Moreover the scheme is isolated from the main built up area of Port Erin and surrounded by open areas, including public footpaths. These areas are protected from development in the Statutory Plans so should remain open in the future. It is therefore argued that while it is important and appropriate to provide space around the development strict adherence to defined policy standards, including the category breakdown, is completely inappropriate. What is needed is open space appropriate to a mixed-use development of this scale. In this I am echoing the wording of the policy, which states that the standards in Table 6 should only be applied ‘where appropriate.’
To confirm this assertion regarding open space it is appropriate to review what is proposed in the development. There are two areas of flat amenity space within and surrounding the scheme. As required by Recreational Policy Area 3 these will be an integral part of the design as demonstrated
in the Proposed Master Site Plan, submitted as part of this application. Within the red line area of the planning application the total public open space should be in the order of 811.7 sq.m. (See attached marked up plan) Additionally, as the plan shows there are significant open areas associated with the cliffs surrounding the development within the redline boundary. As the plan also shows there are significant and larger open areas immediately to the north and east of the site that are just outside the red line boundary.
It is expected that the balcony and patio areas of the proposed apartments should total 1,350 sq. m. For the type of accommodation offered, namely flats and not ordinary dwelling houses this is significant and also of benefit to residents.
Consequently, it is argued that a high quality mixed-use scheme can be provided, which provides adequate facilities for the future residents. In my opinion the planning balance points firmly towards the acceptance of these proposals given the Statutory Policy position and other material planning considerations raised in this letter in regard to the issues of affordable housing and open space, which I have been asked to address.
Yours sincerely, Peter Wilkinson Managing Director Landmark Planning Ltd, 10 Salisbury Road, Leicester, LE1 7QR T: 0116 2856110 E: [email protected]
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