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Mr D Humphrey Senior Planner Heritage Homes Limited Park House Isle of Man Business Park Cooil Road Braddan IM2 2SA
Murray House, Mount Havelock, Douglas, Isle of Man, IM1 2SF email: [email protected] Tel: (01624) 685947 Fax: (01624) 686443 Director of Planning & Building Control M.I. McCauley, M.R.T.P.I.
Please reply to Anthony Holmes, Planning Officer 17th August 2004 Our ref: 03/00790/B & 03/01846/B Dear Mr Humphrey Re: PA 03/00790/B & 03/01846/B – Development off Gardeners Lane, Ramsey.
With regard to your submission relating to the two above planning applications I would advise that the Department has reviewed your draft submission documents and we would make the following comments.
Given that your main statement draws all your information and thoughts together I have concluded that it is simplest if the paragraph number is listed followed by any comments. Therefore the comments on your main statement are:
Paragraph 1.3 - There are various references throughout your statement to Plan No 1, Plan No 2, etc. Whilst lacking in the draft submission it is assumed that these various plans will form part of the formal submission.
Paragraph 1.5 - You have stated that PA03/01846/B proposes 46 dwellings yet an examination of the drawing no. 2291.10a shows a development of 50 dwellings.
Paragraph 2.1 - See comments for paragraph 1.3.
Paragraph 3.1 - See comments for paragraph 1.3. Reference is made to the dry water balancing feature within area 3 contributing to public open space provision. The Department are concerned about the actual usability of this, as it is not usable open space.
Paragraph 3.2 - The inclusion of the fenced hard surface ‘all’ (should this be ball?) court is welcomed by the Department but how the existing nearby residents and others may view this addition is questionable.
Paragraph 3.5 - The use of the phrase ‘intended to complete’ raises some concern and we are unsure as to how a process for ensuring the subsequent completion of the access roads to an acceptable standard would work.
Paragraph 3.6 - Is there any particular reason why 5.9 metres AOD is used when my understanding is that the figure referred to in the West Ramsey Development Framework is 5.75 metres AOD? The West Ramsey Development Framework requires the detailed construction design of flood protection measures to form part of the current planning applications, we are uneasy with the detail construction design of the bank being developed following additional further site investigation. We would not recommend that this is dealt with by condition. Furthermore, we would expect any flood protection measures to be constructed prior to the construction of any dwellings, not prior to the occupation.
Paragraph 3.8 - It would be preferable if any new planting were shown on the submitted drawings.
Paragraph 3.9 - The principle of development on an individual plot basis still raises concern and the Department is uneasy with the potential for piecemeal development of this area. Further explanation of this should be provided.
Paragraph 3.10 - Similarly to the comment for 1.5 have you have stated that 46 dwellings are proposed for area 4 yet an examination of the drawing no. 2291.10a shows a development of 50 dwellings. See comments for paragraph 1.3.
Paragraph 3.13 - We have understood that Ramsey Town Commissioners, the Department of Transport Drainage Division and the Department of Agriculture, Fisheries and Forestry Freshwater Fisheries would not accept the disposal of surface water into the Auldyn River in this location and have no evidence to change this view. If this situation has changed we would expect supporting evidence from those bodies.
Paragraph 4.2 - See comments for paragraph 1.3.
Paragraph 4.7 - It is accepted that the West Ramsey Development Framework should correctly state that there ‘should be a minimum of 2 hectares of land for use as recreation/play area on the land west of Gardeners Lane (notated “4, 5 & 6” on the key diagram)..’
Paragraph 4.9 - Your draft statement contains a rogue d). Is this a typing mistake or should there be something under d)?
Paragraph 4.10 - Given the nature of the sites full flood protection measures that have been designed in accordance with and approved by the relevant bodies is expected with the planning applications. It is considered that the current planning applications do not provide sufficient detail about the design of flood protection measures.
Paragraph 5.2.5 - As noted earlier it is accepted that the West Ramsey Development Framework should correctly state that there ‘should be a minimum of 2 hectares of land for use as recreation/play area on the land west of Gardeners Lane (notated “4, 5 & 6” on the key diagram)..’. Whilst we do not accept your argument that a civic amenity site would conflict other uses with this area it is now understood that a civic amenity site is being pursued elsewhere.
Paragraph 5.2.8 - In terms of your opinion regarding the siting of formal open space in parts not suited to built development we are concerned that this could result in unusable open space that is essentially worthless. Consequently, we are concerned over the level of usable open space provision within area 3. We also consider that in terms of the overall development of 229 dwellings, other than the fenced ball court, there is a lack of appropriate ‘kick-about’ play provision.
Paragraph 5.2.9 - We note your consultation with the Architectural Liaison Officer and welcome the various changes that have been made to the layouts.
Paragraph 5.3.1 - It would be useful if this could be shown on a separate plan. Paragraph 5.3.2 - It would be useful if this could be shown on a separate plan. Paragraph 5.4.5 - This ties in with our concern with this the area being developed on a individual plot basis.
Paragraph 5.5.5 - You state that the analysis has been accepted by the Department of Transport. Whilst this may be true we have no evidence to substantiate this and given the effect this has on phasing we will need some as part of the planning applications.
Paragraph 5.6.1 - As noted previously, see comments on 3.13, we have concerns regarding the surface water drainage of area 4 into the Auldyn River.
Paragraph 5.6.2 - We understood that Ramsey Town Commissioners and the Department of Transport had concerns about the water attenuation feature in terms of its design and its adoption. We have nothing to suggest that these issues have been addressed and overcome.
Paragraph 5.6.5 - See comments for paragraph 5.6.2. It is unclear how the drainage system will have sufficient capacity to cope with the short term overload conditions.
Paragraph 5.7.3 - The detailed design of the flood protection measure will need to be submitted as part of the planning application. If approval is granted it is likely to be subject to a condition requiring the implementation of the flood protection measures before the construction of any dwelling in area 3.
Paragraph 5.7.4 - There is currently nothing to substantiate this statement from either Ramsey Town Commissioners or the Department of Transport Drainage Division. Such substantiating evidence will be required as part of the planning applications.
Paragraph 5.8.3 - In terms of hydrological impact of the development is there any evidence that no part of the existing salt marsh will affected? What is meant by ‘best practices will be implemented’?
Paragraph 5.8.4 - Again this directly relates to the detailed design of the flood protection measures, which at present are not included within the planning applications. We consider that such detailed information is needed within the planning applications.
Paragraph 5.8.5 - How do you propose to undertake ‘appropriate ecological surveys’?
Paragraph 5.10 - Evidence has been put forward by Manx National Heritage of historical events that may give rise to archaeological interest in the West Ramsey Development Framework area. However, given the lack of specific knowledge of particular areas of interest we would, if approval is granted, expect to use a standard condition relating to access for recording in the event of anything of archaeological interest being discovered.
Paragraph 5.12 - As previously noted we still have concerns about the self-build plots.
Paragraph 6.9 - We do not have objections to the development of the sites, we simply want to ensure that they are developed in a manner that address the various complex issues of the West Ramsey area.
Generally, in terms of the revised design and layout of the sites it is appreciated that you have undertaken consultation with the Police Architectural Liaison Officer. The resultant layouts are considered to be an improvement on earlier designs.
The Department remains concerned over the addressing of the hydrological issues within the planning applications and particularly the issues of surface water drainage into the Auldyn River, the flood attenuation pond and the detailed design of flood protection measures. More specifically the issue of surface water drainage into the Auldyn River needs clarification and supporting evidence from the respective drainage authorities submitted if appropriate. The issue of the flood attenuation pond need to be addressed further as we understand that Ramsey Town Commissioners and the Department of Transport Drainage Division have issues over its design and adoptability. In accordance with the West Ramsey Development Framework how the flood protection measures will work needs to be demonstrated to the satisfaction of Ramsey Town Commissioners and the Department of Transport Drainage Authority. At present the specific detail of the flood protection measures remains vague and needs to be addressed as part of the planning application.
We also still have some have concerns over the open space provision for the area. Taking into account all the planning applications, from which we calculate there is the potential for 229 new dwellings, there seems to be a lack of suitable ‘kick-about’ play provision. Whilst we welcome the additional ‘kick-about’ play area in area 2 it is considered that further provision is needed. In particular the open space provision proposed within area 3 is the flood attenuation pond and we would question its actual worth as usable open space. We would like to see further usable open space provision within area 3. Has the possibility of providing further ‘kick-about’ play provision
in the south eastern corner of area 6 tied into the current planning applications been considered? At some point in the development of West Ramsey such provision will be required and the Department is not prepared to accept the issue being left for the later phases of development, possibly never happening.
On a general note it would be useful if you could provide evidence of where consultation has been undertaken with bodies such as Ramsey Town Commissioners and the Department of Transport and what the outcomes were.
In terms of progressing the applications I would suggest that you address the issues raised in this letter and then make a formal submission. On a practical note when you do make the formal submission given the amount of drawings that we now have it would be useful if you could supply a issue sheet detailing the drawings that are to be considered as part of the planning applications.
Should you wish to discuss this matter please do not hesitate to contact me.
Yours sincerely
A. Holmes Anthony Holmes Planning Officer
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