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January 2005
Lovejoy 1 Fore Street Birmingham B2 5ER Tel : 01213297676 Fax: 01213297677 E-mail: [email protected]
1.0 Introduction ..... 1 2.0 Description of the Sites ..... 4 3.0 The Proposed Development ..... 6 4.0 Development Plan Context ..... 12 5.0 Issues in relation to the Applications ..... 16 6.0 Conclusions ..... 28 PLANS AND APPENDICES Plan 1 Application Sites Location Plan Plan 2 Site Layout Area 2 Plan 3 Site Layout Area 3 Plan 4 Site Layout Area 4 Plan 5 Extract from West Ramsey Development Framework March 2004 Appendix 1 Letter of 17 December 2003 from Director of Planning and Building Control
1.1 This statement relates to two separate planning applications submitted by Heritage Homes Limited in respect of land at Poyldooey, Ramsey. The two sites lie adjacent to Gardeners Lane, to the west of Ramsey, north of Lezayre Road and south of the Sulby River. The development of the two sites - for residential and for residential/ commercial development respectively - give rise to a number of issues that require detailed consideration. This statement provides additional information in respect of those issues. 1.2 Whilst the statement deals with both the individual and combined effects of the prospective development of the two application sites, for reasons of clarity, the sites have been identified separately throughout the statement. For simplicity, the sites are identified in this statement using the numbering references set out in the text and key diagram of the West Ramsey Development Framework (WRDF) published by the Department of Local Government and the Environment (DoLGE) in March 2004. The detail of the WRDF is further considered in the statement below. 1.3 Land lying to the east of Gardeners Lane and proposed for residential development, is in two parts; Area 2 relates to land lying between the line of the former Ramsey to Kirk Michael railway line (now disused) and the proposed line of a new distributor road; Area 3 comprises land north of the proposed distributor road and extends as far north as the Poyldooey Nature Reserve. Area 4 comprises land lying to the west of Gardeners Lane, extending to Auldyn River. The sites are shown on Plan No 1. 1.4 All of the areas are allocated sites for residential development in the approved Ramsey Local Plan. The local plan was approved by Tynwald in November 1998 and was operational from 1 December 1998. The allocations in respect of the areas anticipated that the development of land would only be undertaken in accordance with an overall scheme of development for the wider west Ramsey area. The respective policies applying to each site anticipated, in respect of Areas 2 and 3, that provision should be made for residential development, light industrial use, recreational play area, and landscape space adjacent to the rivers (Sulby and Auldyn), the former railway line, and around Poyldooey House; and that in respect of Area 4 (which included land to the west of the Auldyn River) mixed density housing and a primary school site, with light industrial development on the eastern part of the site. 1.5 The sites have been subject to previous planning applications. Although permissions were granted in 1987, for a stable block (PA 87/1802); in 1988 (at review) for industrial unit (PA
87/1945); and in 1991 (at appeal) for mixed residential/business/industrial development (this last consent (PA 91/1487) broadly coincides with Areas 2, 3 and 4) none of these previous permissions were implemented in whole or part. Application PA00/2042 was submitted by Heritage Homes Ltd. in respect of Areas 2 and 3 in December 2000 but was withdrawn in July 2003 when the current application (PA03/0790) was submitted. Application PA03/0790 (as revised) proposes the residential development of 175 plots with road, sewers, public open space and landscaping, and detailed approval for the construction of 137 dwellings (on Area 2). Application PA02/01909 was submitted by Heritage Homes Ltd. in December 2002 in respect of Area 4. That application was withdrawn in December 2003 in favour of the current application on Area 4 (PA03/01846B) which (as revised) proposes the development of roads, sewers and 46 dwellings and a neighbourhood centre comprising public house (with managers accommodation) children's nursery and two shop units with four apartments over.
1.6 The Director of Planning and Building Control of DoLGE set out, by letter dated 17 December 2003, to Heritage Homes Limited, a list of issues relating to the development of the sites, which had arisen both from consultations on the current and earlier applications, and in respect of the West Ramsey Development Framework (see below). A copy of the Director's letter is at Appendix 1. The specific issues identified in the Director's letter are discussed further below, but the central point of the letter was that Heritage Homes Limited should set out, in a comprehensive form, an assessment of certain environmental effects of the development of the two sites, and to consider the environmental effects of the development of the sites both singly and together. This statement seeks to provide the necessary information in response to the letter of 17 December 2003.
1.7 This statement is structured in the following way:
a) Section 2 sets out a description of the application sites;
b) Section 3 sets out a description of the development proposals;
c) Section 4 sets out the development plan context, by reference to the provisions of the approved Ramsey Local Plan (1998), and the West Ramsey Development Framework (2004), which has been adopted as supplementary planning guidance, and to which the Department of Local Government and Environment will have regard to in the determination of planning applications for the development of land;
d) In section 5 the various issues identified in the letter of 17 December 2003 from the Director of Planning and Building Control are considered individually. The issues are divided into core issues - those that are considered to be critical and central to the acceptability of development - and secondary issues - those issues which, whilst of
importance, are not of themselves determinative of the acceptability of development; and e) Section 6 sets out conclusions.
2.1 As noted above, the application sites lie on the western flank of Ramsey, north of Lezayre Road, off Gardeners Lane. The sites (which are described more fully below) are shown on Plan No 1. 2.2 Areas 2 and 3 lie to the east of Gardeners Lane, and to the north of existing residential development at Lezayre Park/ Greenlands Avenue. Together, they form one of the application sites, which extends to some 8.0 hectares ( 20 acres). To the north the site is bounded by the existing Poylldooey Nature Reserve; to the south by the former Ramsey to Kirk Michael railway line (now used as an informal public footpath); to the east the site boundary is undefined; and to the west the site boundary is formed by Gardeners Lane. The site, previously used for pasture, is now fallow and overgrown, with grassland and scrub vegetation developing. The site falls gently from the south west corner from a level of 10 metres AOD to the north east at 4 metres AOD. Within the northern part of the site there is a pronounced shelf where levels drop between 6 and 4.5 metres AOD. There is a slight fall from west to east, particularly in the southern part of the site. To the north of Area 3 lies the Poylldooey Nature Reserve, which extends to, and along, the southern bank of the Sulby River. To the south, beyond the former railway line, lies existing residential development ( 1 and 2 storey) at Lezayre Park. To the east is land formerly in agricultural use, but now fallow, whilst to the west, beyond Gardeners Lane, and comprising Area 4, is grazing land. 2.3 There is a continuous hedgerow to the western boundary to Gardeners Lane of some 435 metres and a fragmented hedgerow on the southern boundary to the former railway line. Within the site are two discontinuous hedgerows - one running east-west, approximately 175 metres in length, the other running southeast to northwest approximately 120 metres in length. There are some isolated individual scrub trees developing within the site, but none of any significance or stature, and a number of more substantial trees on the western boundary to Gardeners Lane, immediately adjacent to the entrance to the property "Greenlands" to the northwest of Gardeners Lane. The site was noted as poor semiimproved grassland in the Phase 1 habitat survey undertaken by DAFF, although it was also noted that the hedgerows may be used by bats and that the grassland may also be used by breeding birds and by reptiles. Agricultural access to the site is available from Gardeners Lane; following the cessation of agricultural use the site has been used for informal casual recreation and a number of tracks have developed across the site. 2.4 Views to the site are primarily restricted to local views from Gardeners Lane to the west, from the former railway line to the south (but also from the upper floors of properties in
Lezayre Park to the south); and from the Poyldooey Nature Reserve to the north. Glimpse views are also available to the site from the Gardeners Lane footbridge where it crosses the Sulby River, and from the informal footpath on the north side of the Sulby River. The site is visible, but is not readily distinguishable in longer distance views, from higher ground to the south, or from residential properties on the north side of Sulby River within Ramsey.
It is proposed that Areas 2 and 3 are developed for residential use, roads, sewers, public open space and landscaping. The proposed layouts are shown on Plan Nos 2 and 3 respectively. In overall terms, 175 dwellings are proposed. 137 dwellings are proposed on the southern part of the site (Area 2) and 38 plots on the northern part of the site (Area 3). It is proposed that Gardeners Lane is extended from the south, where there are two existing separate carriageways, to form a dual carriageway from Lezayre Road leading to a new roundabout, located on the line of Gardeners Lane, between Areas $2 / 3$ and 4. From this roundabout a new district distributor road is proposed to extend through areas 2 and 3 ultimately connecting with Station Road in Ramsey. Within Areas 2 and 3 some 1.74 hectares ( 4.30 acres) of public open space (including a dry surface water balancing feature of c. 0.26 hectare ( 0.65 acres)) and 0.40 hectares ( 1.00 acres) of landscaped areas) are proposed.
Two storey semi detached houses are proposed on the Gardeners Lane frontage, and on part of the distributor road frontage, with the latter accessed via informal service roads aligned parallel to the distributor road. There will also be two short terrace sections of two/ three storeys fronting the distributor road on the eastern part of Area 2, with rear access from within the development. The balance of the site will be developed in two-storey terrace blocks (typically of five dwellings in each terrace), and five three-storey apartment blocks. Parking will be provided at the rate of two spaces for each dwelling, on plot, or in shared parking areas adjacent to groups of dwellings. Within the landscape/ open space areas within the site (discussed more fully below) two play areas are proposed; one for toddlers within the centre of the site, the other, a fenced hard surface ball court is located in the south east of Area 2, in a location where adjacent properties are at some distance, or are orientated gable end on to the plan area (to reduce any noise disturbance), but are still open to active surveillance.
Vehicular access to Area 2 will be solely from the proposed distributor road via two internal loop roads and a series of culs-de-sac. There will be frontage access only to properties on the (new) dual carriageway section of Gardeners Lane.
Pedestrian routes will be located along the realigned Gardeners Lane and the distributor road frontages, with access made available from the path along the disused former railway
to the south and through Area 2. In Area 3, a new pedestrian route providing access to the Poylldooey Nature Reserve will be created within the site parallel to Gardeners Lane, but separated from the Lane by the retained frontage vegetation. Pedestrian access is proposed along part of the frontage of the new distributor road and via a crossing point on the distributor road to link back into Area 2. Further pedestrian routes will be provided, associated with the access culs-de-sac within the development and adjacent to the proposed surface water balancing facility.
Access to Areas 2 and 3 will initially be formed via the improved Gardeners Lane. The new alignment, including the dualing of Gardeners Lane and the formation of the new roundabout and the distributor road between Areas 2 and 3 will be constructed to base course with associated drainage. As development proceeds on Area 2, generally from west to east, the development will be completed to a standard acceptable to the Department of Transport Highways and Traffic Division. In respect of Area 3, access roads within the site will be completed to base course level pending the sale and completion of individual plots, with the access roads subsequently completed by Heritage Homes Ltd to a standard acceptable to the Department of Transport Highways and Traffic Division.
Foul water drainage will drain from Area 2 by gravity to a new sewer to be constructed along the line of the proposed distributor road linking back to the existing Riverside pumping station in Ramsey. Sewerage will be sized to take account of development of land on Area 3, Area 4, further development west of the Auldyn River and the redevelopment of the Lezayre Estate in Ramsey. Foul drainage in Area 3 will drain by gravity to a proposed pumping station to be located in the northern part of Area 3. Sewage will be pumped via a rising main back into the new sewer to return, by gravity, to the Riverside pumping station (as described above). Surface water from dwellings, roads and common areas for both Areas 2 and 3 will be released into the Sulby River by a gravity system, including a new section of underground pipe that will cross the Poylldooey Nature Reserve. Surface water will be stored within Area 3 in a dry balancing pond located in the northern part of Area 3 during periods of astronomical high tides (discussed more fully below). It is proposed to construct a flood wall or earth bank to a height of 5.9 metres AOD along the northern, western and eastern banks of Area 3; a series of cross sections through the proposed bank are included with the submitted drawings. It is proposed that the bank will be constructed prior to the occupation of any dwellings within Area 3. The proposed distributor road will have a minimum elevation of 5.9 metres AOD, and all of the properties within Area 2, south of the distributor road, will have slab heights in excess of 5.9 metres AOD.
Lezayre Park to the south of Area 2 comprises predominantly one and two storey suburban housing based on a loop road and cul-de-sac system. To a degree the proposed layout of development on Area 2 reflects that characteristic and density, although by virtue of the type of housing used (terraced units and apartments) and the incorporation of three storey elements, the average density of the proposed development Area 2 will be higher than that existing at Lezayre Park. The buildings are proposed as simple gabled/pitched form, incorporating hipped and half-hipped roofs. The dwellings will be constructed in a mixture of brick and white render, with the use of feature soldier brick courses for variety, primarily on the ground floor, but also at first floor level in three storey apartment blocks. Feature gables will be incorporated above first floor windows, with double pitch and monopitch porches used to emphasise the domestic character of the proposed development. Roofs will generally be in dark grey concrete tile, with windows in UPVC, highlighted selectively by painted render surrounds. Fencing within the development will typically be 1.8 metre high close-bordered timber.
Within Area 2 the existing hedgerow vegetation to the former railway line to the south will be retained, and parts of the hedgerow (ca 120 metres) on the western side of the boundary to Gardeners Lane will be retained within the central reservation of the proposed new dual carriageway section of Gardeners Lane. Part of the existing hedgerow which runs east-west across the site (approximately 90 metres) will be retained within the landscape area south of the proposed distributor road. On the Gardeners Lane and distributor road frontages new tree planting will be developed to define a new avenue character. In addition, new planting will be provided on the (presently undefined) eastern boundary, and reinforcement planting is proposed to the boundary to the former railway line to the south. Within the main developed part of Area 2 there will be substantial tree planting within the main public open space/ play area located in the south western part of the site, and on road frontages within and adjacent to car parking areas. Short avenues of trees are proposed on property frontages on the internal loop roads within the site. New planting in Area 2 is shown on Plan No 2.
The detailed designs of the proposed dwellings to be developed on the individual plots do not form part of this application. It is intended that some of these plots will be made available for sale to individual purchasers/developers; other plots may be developed by Heritage Homes Ltd. The concept of an estate layout within which individual plots are developed by various parties is not inherently different from 'conventional' development in that the development structure (roads and sewers) is established and, subject to the grant
of specific planning permission, individual plots or groups of dwellings are developed subsequently. Whilst no details are proposed, at this stage, in respect of building design on Area 3, the layout anticipates they will be predominately two storey dwellings. Access to Area 3 will be solely from the proposed distributor road, with no frontage access to either the distributor road or Gardeners Lane. A series of culs-de-sac will provide access to 38 development plots. The existing vegetation frontage to Gardeners Lane, although broken in part to provide for the construction of the roundabout and local realignment of access into the northern part of the Lane, will be retained as at present. The existing planting on the frontage to the Poylldooey Nature Reserve to the north will not be affected. Part of the existing east - west hedgerow -some 95 metres in length - will be retained north of the distributor road. To reflect proposed avenue tree planting in Area 2 to the south of the distributor road, similar avenue tree planting is proposed along the northern side of the distributor road between the distributor road and the access culs-de-sac in Area 3. Further tree planting is proposed around (but not within) the dry balancing area located in the northern part of Area 3. As noted above, it is proposed to construct a floodwall or earth bank to a height of 5.9 metres on northern western and eastern banks of Area 3 and further tree and shrub planting is proposed in association with this feature. New planting in Area 3 is shown on Plan No 3.
In respect of Area 4 it is proposed to develop 46 residential properties and a neighbourhood centre comprising public house, nursery, and two shop units (with four apartments over, resulting in a total of 50 residential units overall). The proposed layout is shown on Plan No 4. Area 4 is defined by existing land uses/features to the east west and south, with housing in the south and west of the site and the commercial uses in the north east corner. The total gross floor space of the retail use is 250 square metres ( 2690 square feet). It is anticipated that one of the units will be used as a convenience store, and the other as a takeaway food shop. Access to the site will be from the proposed extended (dual carriageway) Gardeners Lane and roundabout. The commercial development will be located in the southwest quadrant of the proposed roundabout, with housing located beyond to the west/south. An area of car parking is proposed fronting on to the new distributor road frontage to the north of the commercial development. A small area of public open space/play area ( 0.10 ha ( 0.25 acres) is proposed on the frontage to Gardeners Lane where the existing hedgerow will be retained (save for part of its northern end which will require to be removed to form the roundabout). Some 0.10 ha ( 0.25 acres) of public open space is proposed in association with the new footpath adjacent to the Auldyn River. In addition, a further 0.10 hectares ( 0.25 acres) of landscaped area is proposed.
There will be no vehicular access from the development directly on to Gardeners Lane. Two accesses are proposed onto the short section of the distributor road leading west from the new roundabout to serve, respectively, the commercial and residential uses. The distributor road will provide access to land lying to the west of the Auldyn River, and will be constructed of sufficient width and specification to cope with the traffic arising from further development to the west of the Auldyn River.
Pedestrian access to the site will be solely via the northern part of Gardeners Lane, the frontage to the new roundabout and from the new distributor road. Access will be provided from within the development to a crossing point on Gardeners Lane to provide a link with Area 2. A new public footpath is proposed along the western side of the site between the rear of semi-detached properties and the retained woodland belt adjacent to the Auldyn River.
Surface water will be disposed of by gravity into the Auldyn River. Foul water will drain by gravity to a proposed pumping station located on the north side of the proposed distributor road. From the pumping station a rising main will return to the existing gravity system within the Lezayre Park development, from where it will drain by gravity back into the existing system in Ramsey. No part of Area 4 is affected by flooding, and all of the proposed development (roads and dwellings/commercial uses) is proposed to be constructed at levels in excess of the 5.75 m AOD maximum local flood level.
As with Areas 2 and 3 the proposed development on Area 4 reflects the character of Lezayre Park to the southeast but is at a higher density. The proposed development will comprise two/three storey houses - primarily semi detached, with two terraced blocks of four/six units located in the south of the site adjacent to the boundary to the industrial uses. The dwellings will be of simple gabled form with textured/ plain render facings with grey concrete roofs, with the front elevations articulated by double and mono pitch porches. The public house will be primarily single storey with a second storey manager's apartment above, in white render, with a Manx stone plinth and brickwork quoins. The shops with apartments over will be of similar architectural style to the proposed semi detached houses. The nursery/ crèche will be a single storey building, with white render walls and a brickwork plinth, and grey concrete tile roof. Parking for 47 cars for customers/visitors is proposed on the north side of the commercial uses adjacent to the distributor road. Parking for
residential uses will be provided at the rate of two spaces for each dwelling, on plot, or in shared parking areas to the rear of groups of dwellings. Fencing to properties will be 1.8 metre high timber fencing.
In respect of landscape structure, the existing hedgerow on the western side of Gardeners Lane will be retained save for approximately 58 metres, which will be removed to allow for the construction of the new roundabout. All of the existing trees on the bank of the Auldyn River will be retained. The existing hedgerow on the southern side of the site adjacent to industrial uses will be retained and reinforced by additional tree planting. The frontages to Gardeners Lane, adjacent to the toddlers play areas/ open space and adjacent to the public house, will be reinforced by additional tree planting. New tree planting, to reflect the avenue approach adopted in respect of areas 2 and 3 is proposed to be developed on both sides of the distributor road west of the new roundabout. Within the development itself tree planting is proposed in front gardens along the access cul-de-sac, to the rear of properties at the back of longer private gardens, and as a substantial belt of planting, within the rear of the service area to the commercial uses, between the residential and commercial uses. New planting is shown on Plan No 4.
4.1 In the Ramsey Local Plan (Planning Circular 2/99) Areas 2 and 3 are within an area designated for Proposed Predominately Residential use. This designation was carried forward from the Isle of Man Planning Scheme (Development Plan) Order 1982. The Ramsey Local Plan requires that the development within this area should be undertaken "in accordance with an approved scheme for the whole area" and that a school should be provided within the residential area if required by the Department of Education. Area 4 forms part of a larger area designated for mixed Residential and Light Industrial use in the Local Plan. The Plan requires an overall scheme for the area to be prepared, with a minimum of 3 hectares of land to be used for light industrial purposes, and a minimum of 2 hectares of recreation land/ play area. The Plan also indicates that open landscape areas should be provided alongside the Sulby River and adjacent to Poyldooey House (although this latter reference may be a mistaken reference to Greenlands, as Poyldooey House lies further to the east). 4.2 A Consultation Draft West Ramsey Development Framework (WRDF) was published in January 2003, and following public consultation, the approved WRDF was published in March 2004. The WRDF constitutes supplementary planning guidance, which is in accord within the provisions of the Local Plan, and to which regard will be made in the determination of planning applications for the development of land. An extract from the WRDF Key Diagram is at Plan No 5. 4.3 In respect of land use allocations, the WRDF proposes that Area 2 should be developed as medium/high density development (between 15-30 dwellings per hectare) giving a total of between 75-150 dwellings (WRDF paragraph 5.2.2). Area 3 is proposed for low density development of between 12-15 dwellings per hectare, and could thus give rise to some 6075 dwellings (paragraph 5.2 .1 of the WRDF refers), although the suitability for development of the site is noted as being dependant on the requirements for flooding protection and drainage. Area 4 is proposed for a neighbourhood centre to serve the new residential development and new industrial development, and to provide a range of neighbourhood services including shops, a health centre (including doctor and dentist surgeries), a meeting hall, and possibly a church, public house and nursery/ crèche. It is acknowledged that these uses could be integrated with flats and sheltered housing, and that such land within this general area, which is not needed for the neighbourhood centre, should be developed for medium/high density housing. No quantum of housing is provided for in the WRDF in respect of Area 4 (WRDF paragraph 5.2.3).
4.4 Paragraph 5.4 of the WRDF sets out the importance of design issues, explains how development should reflect local character, and illustrates possible local references. The need for a Design Statement is noted. In addition, in relation to residential development, the WRDF notes the need for energy efficient design (Paragraph 5.5), to reduce the opportunities of crime through considered design (paragraph 5.7 and Appendix 2), and to provide car parking to comply with the established minimum standards set out in the Isle of Man Planning Scheme (Development Plan) Order 1982. Paragraph 5.3 deals with affordable housing, and explains that against the background of policies set out in the Draft Strategic Plan (2001) individual sites will be expected to provide affordable housing, although the particular number of dwellings and means of provision will be a matter for negotiation in respect of individual planning applications.
4.5 Paragraph 9.1 of the WRDF deals with education requirements and acknowledges that existing and currently proposed new/replacement primary school facilities will meet educational needs arising from housing within WRDF area, and as a consequence no provision needs to be made for a school site within the overall site.
4.6 Within paragraph 10.1 of the WRDF attention is drawn to the need for generous landscape spaces alongside the river and former railway line, and around Poyldooey House (although it is not clear whether this is intended to be a reference to Greenlands as opposed to Poyldooey House).
4.7 In respect of open space, paragraph 10.1 of the WRDF notes a minimum of 2 hectares of land should be made available for recreational/play facilities on land west of Gardeners Lane. This requirement is brought forward from the Ramsey Local Plan. Although the printed text of the WRDF indicates that 'land west of Gardeners Lane' is notated as Area 4 on the key diagram, subsequent correspondence from DoLGE (letter of 17 August 2004 to Heritage Homes Ltd) confirms that this should refer to Areas 4, 5, and 6 on the key diagram. In addition, as also noted at paragraph 10.1 of the WRDF, provision should be made within new residential development of toddlers play space and children's kick-around facilities in accordance with standards set out in the Draft Strategic Plan Appendix 4 (July 2001).
4.8 Section 11 of the WRDF deals with nature conservation. It is acknowledged at paragraph 11.2 that certain features of the locality would be affected as a consequence of development, but that hedgerows and trees should be retained wherever possible and that the area of salt marsh adjacent to the Sulby River should neither be disturbed, nor affected adversely by drainage arrangements.
4.9 In respect of highways/transportation, it is acknowledged in the WRDF that:
a) There is no need for a second crossing of the Sulby River referred to in the Ramsey Local Plan at paragraph 3.9 (WRDF paragraph 13.1).
b) A new distributor road should link Poylidooey Road to Gardeners Lane (WRDF paragraph 13.2).
c) Gardeners Lane should be widened between the former railway line and the junction with the new distributor road, with existing road side trees/ vegetation retained if possible and incorporated in a central reservation, whilst north of the new distributor road, the existing attractive rural character of Gardeners Lane should be retained (WRDF paragraph 13.3).
d) The former railway line should be formally established as a public footpath, and that links to that footpath should be created from the development or redevelopment of land within the framework area, including links to the existing Poylidooey nature trails (WRDF paragraph 13.5).
4.10 In respect of flooding, the WRDF notes at paragraph 15.2 that a 1 in 200 tidal event would give rise to a tide level at Poylidooey of 5.75 metres AOD and that, consequently, new housing in the Poylidooey area should be built in a way that protects it from flooding at a level of 5.75 metres. It is important to note that the flood risk in respect of the area arises primarily from the effect of astronomical high tides. The WRDF is not prescriptive about how such flood protection should be secured, and acknowledges that "this can be done in a number of different ways." It states that any planning application will require to demonstrate how flood protection will be provided, and notes that specific proposals will need to be the subject of detailed discussion with relevant parties, including the Drainage Division of the Department of Transport and Ramsey Town Commissioners.
4.11 In respect of drainage, the WRDF indicates at paragraph 16.2 that foul sewage should be collected by gravity, to the pumping station at Riverside, but acknowledges that where this is not practical, it may be pumped to a point from where it can then be drained by gravity to the pumping station (at Riverside or elsewhere), subject always to the agreement of the Drainage Division of the Department of Transport. It further notes that foul sewers should be of sufficient capacity to carry the loads which might reasonably be anticipated once other land with the WRDF area, and land further west in Lezayre, has been developed, and that all sewers should be laid under highways or other public accessible land (WRDF paragraph 13.2). It is acknowledged that the surface water run off from roofs and paved areas will ultimately drain to the Sulby River, and that there may be a requirement for attenuation tanks or ponds to slow down the rate of run-off and reduce the likelihood of river flooding during periods of heavy rain fall and to store surface water when tidal conditions prevent the discharge of flows into the river. (WRDF paragraph 16.3).
4.12 Paragraph 12.1 deals with archaeology, and notes that as the West Ramsey area is understood to contain sites of archaeological importance, all planning applications should include an archaeological assessment, including an appropriate method statement.
4.13 Paragraph 8.1 of the WRDF notes the need for a civic amenity site to serve the north of the island and indicates that preferably such provision should be made in Area 4, although it is acknowledged that if this area is not suitable, then an alternative location should be found elsewhere within West Ramsey. To accommodate that development will either limit or preclude the use of this area for other uses (noted above) that are suggested as being appropriate in that area. It is now understood that a site outside of Area 4 is being considered for civic amenity use.
4.14 In respect of phasing, the WRDF notes at paragraph 17.1.2 that the development of Areas 2, 3 and 4 must include highway and infrastructure to support the level of development proposed. It further notes that as part of the development of Areas 2, 3 and 4, provision should be made to ensure that the distributor road links into land to the east, and into land to the west of the Auldyn River.
5.1 As noted above, the issues in relation to the applications, as identified from the letter of 17 December 2003 from the Director of Planning and Building Control can be separated into core issues and secondary issues. The core issues relate to the following
The secondary issues relate to other matters raised in the Director's letter, which are not considered to be critical to the planning acceptability of the development. These are;
These are each considered further below.
5.2.1 The land uses proposed in respect of areas 2,3 and 4 are consistent with the provisions of the WRDF. Areas 2 and 3 provide for residential development east of Gardeners Lane and north and south of the proposed distributor linking Gardeners Lane and Station Road, Ramsey. Area 4 provides for a neighbourhood centre, albeit with a range of facilities less than that presented in the WRDF, with the balance of the site used for residential development. 5.2.2 Area 2 provides for some 137 dwellings. The WRDF (paragraph 5.2.2) suggests that the site could provide between 75-150 homes. The provision on Area 2 is therefore consistent with the provisions of the WRDF. 5.2.3 Area 3 provides for the development of 38 dwellings. The WRDF indicates that paragraph 5.2.1 that such development should be at a lower density than Area 2 to the south and that
it could provide for some 60-75 homes. There are two reasons for the apparent shortfall: first the area described in paragraph 5.2 .1 of the WRDF is larger than that for which permission is now sought in respect of Area 3. Second, the calculation of potential dwelling yield in paragraph 5.2 .1 of the WRDF did not take account of any area of land required to provide surface water balancing facilities or open space. Thus whilst the quantum of housing yield from Area 3 appears to be less than that identified in WRDF at paragraph 5.2.1 the principle of development of lower density development, as set out in the WRDF, has been achieved. 5.2.4 In respect of Area 4, paragraph 5.2 .3 of the WRDF sets out an aspiration in respect of the range of uses to be accommodated within the neighbourhood centre. Heritage Homes do not consider that there is any proven demand for certain of the facilities identified in paragraph 5.2 .3 of the WRDF. This approach has been confirmed during discussions with the Planning Officers and other Government Departments. It is accepted that a sensible scale of provision will be for a modest amount of retail floor space ( 250 square metres 2760 square feet gross floor area) plus a nursery/crèche and a public house. The balance of Area 4 is proposed to be developed for housing. Thus whilst the precise type and extent of development proposed does not expressly meet all of the facilities described in paragraph 5.2 .3 of the WRDF, the principle of development i.e. neighbourhood centre incorporating community and commercial facilities, with a residual development of housing, is reflected by the proposals in respect of Area 4. 5.2.5 The WRDF identifies a number of possible uses that could be accommodated in Area 4, including a neighbourhood centre, housing, open space, and a civic amenity site. The key diagram indicates that the site should be used for a neighbourhood centre, although the physical extent of the site is greater than the area needed, or which can be justified, for such a centre. In order to achieve a sense of place it is important that Area 4 should contain built development, which in both land use and design terms, located at the junction of the distributor road and Gardeners Lane, forms a pivotal core to development at West Ramsey. That can be best achieved through the use of Area 4 for the neighbourhood centre and for (relatively) higher density housing. 5.2.6 In terms of development character and in relation to the objective to create a distinct sense of place, it is apparent that by virtue of their location, Areas 2,3 and 4 lie on the existing edge of the Ramsey built up area. Once developed, they will in practice provide part of the enduring interface between the existing suburban residential development at Lezayre Park, and land to be retained in open land use (Poyldooey Nature Reserve and adjacent open land).
5.2.7 The character of the built development in the local area, at present, is essentially suburban. Whilst the development proposed entails increased densities on Areas 2, 3 and 4, above those at Lezayre Park, the character of the area following development will remain essentially as it is. It would not be appropriate, given the existing character of the surrounding area, to adopt a more 'urban' approach; that would not only be at odds with local landscape and built development characteristics, but it would also sit uneasily on the edge of the interface with open countryside beyond, and be inconsistent with the essential character of Ramsey as a free standing small town, where higher density urban development is necessarily focused in and around the town centre and harbour, and not, to any significant extent elsewhere within the town, let alone on the urban edge. 5.2.8 Requirements for open space are set out in Appendix 6 of the Isle of Man Strategic Plan (Modified Draft November 2004). Paragraph A6.2 sets out the basis of quantitative calculation of open space, which is broken down into formal open space, childrens play space and amenity open space. The overall requirement deriving from the proposed development, assuming an average household size of 2.37 persons (the all-island average figure from the 2001 census, with the average household size for Ramsey being 2.16 persons) would therefore be 1.68 hectares. As noted above, the development will provide some 1.74 hectares of open space, including land that would be used, occasionally, for surface water balancing. Surface water balancing areas have previously been accepted in the Isle of Man as useable open space, e.g. at Truggan Road/ Droghadfayle Road, a Port Erin development which was approved at appeal (PA 01/01720). Paragraph 10.1 of the WRDF (as revised - see 4.7 above) makes it clear that the local provision for formal open space, children's play space and amenity open space should be made within the new residential areas, and is in addition to the strategic allocation of open space of 2.0 hectares on land west of Gardeners Lane. Although the WRDF is silent on how that strategic allocation of open space is to be secured, Heritage Homes Ltd take the view that formal open space should be provided to serve the whole of the West Ramsey development, and confirm that they are prepared to contribute towards that provision. 5.2.9 Appendix 2 of the WRDF sets out guidance on how crime prevention and reduction measures can be incorporated into the design of development. The guidance is necessarily general, but following discussions with the Architectural Liaison Officer of the Isle of Man Police, a number of changes have been made to the respective site layouts. The following elements of the layout for Areas 2, 3 and 4 indicate how considerations relating to crime prevention have been applied:
5.3.1 It is acknowledged as part of the development certain of the existing (albeit limited) landscape infrastructure in the locality will be lost. Some 50 metres of the hedgerow on the east side and some 58 metres on the west side of Gardeners Lane will be lost as a consequence of the formation of the new roundabout and the widening of Gardeners Lane between Lezayre Park and the new distributor road. Two separate sections of 60 metres length of the existing hedge on the east side of Gardeners Lane will be retained within the central reservation to the new dual carriageway. North of the proposed roundabout/distributor road, a further 25 metres of the existing hedgerow on the east side of Gardeners Lane will be lost where the northern section of Gardeners Lane is realigned to form a new junction to the proposed distributor road. The balance of the frontage vegetation further north on Gardeners Lane leading up to the Poyildooey Nature Reserve will be retained in its entirety. 5.3.2 Approximately 55 metres of the existing east-west hedgerow (out of a length of some 240 metres) will be lost through the construction of the distributor road, but in total some 185 metres of this hedgerow will be retained north and south of the proposed distributor road.
The other hedgerow within the northern part of Area 3 will be removed in its entirety. The existing hedgerow along the southern boundary of Area 2 adjacent to the former railway line will be retained in its entirety, and the existing riparian vegetation adjacent to the Auldyn River, on the west side of Area 4, will also be retained in its entirety.
In addition to the significant elements of existing vegetation to be retained, new avenue tree planting is proposed on the new carriageway to Gardeners Lane (particularly on the east side but also behind the retained hedgerow on the west side of Gardeners Lane), and to the north and south of the proposed distributor road (east and west of Gardeners Lane). In addition tree planting is proposed within the centre of the new roundabout. Supplementary underplanting is proposed in association with the retained vegetation adjacent to the Auldyn River, and on the north side of the railway line adjacent to both Areas 2, 3 and 4. Substantial areas of woodland planting are proposed on the flood bank to be constructed to the north, east and west of Area 3. In addition internal tree planting and areas of shrub planting are proposed within the respective development sites in association with areas proposed for toddlers play space, children's play space, and public open space.
The development of Areas 2, 3 and 4 will reduce the physical extent of open land that lies between Greenlands and Poyldooey House and existing urban development to the south, but through the retention of existing landscape features and the incorporation of new and enhanced landscape features, there will be no adverse affect upon the setting of either property.
The initial stage of development of the sites will involve the formation of the widened section of Gardeners Lane between the Lezayre Park estate and the new roundabout, and the formation of the section of distributor road through Areas 2 and 3 and into Area 4, completed to base course level. At the time of construction of these sections of road, the foul sewer will be constructed between Area 4, along the future line of the proposed distributor road through to Station Road, and the Riverside pumping station. The rising main between the proposed pumping station to serve Area 4, and the existing sewerage system within Lezayre Park will also be constructed at this stage.
The initial phase of building development will commence in Area 2 and will proceed generally from west to east developing properties on the widened and realigned Gardeners Lane frontage initially, subsequently extending further to the east.
5.4.3 Either consecutive with or consequent to the completion of development on Area 2, the development of Area 4 will be commenced, with the commercial facilities in the south west quadrant of the new roundabout preceding the construction of housing development within the site. 5.4.4 As part of the development of Area 2, and in advance of the development for housing on Area 3, the flood embankment on the north, east and west sides of Area 3 will be constructed, along with the surface water balancing facility. 5.4.5 Consequent to the development of Area 2 and Area 4, the development of Area 3 will progress, although the precise phasing of development will be limited by the take up of selfbuilt plots (see below).
5.5.1 The alignment of the principal access roads into the site has been determined by two principal factors. First, the alignment of Gardeners Lane is essentially given, and as a consequence, the alignment of the new dualled section of Gardeners Lane is in practice determined by the need to retain existing vegetation within the central reservation. The alignment of the distributor road between Gardeners Lane and Station Road in Ramsey has been so arranged to provide adequate plot depth on either side of the distributor road, particularly given that in this area the overall depth of land available for development is narrower than in respect of areas 2 and 3. The new foul water drain connecting the planning application sites to the existing pumping station at Riverside will follow the same alignment as the distributor road, and will be sized to accommodate flows from future development further to the west (beyond the Auldyn River) and from the redevelopment of the Lezayre Estate in Ramsey (although the Ramsey Town Commissioners will need to confirm the nature of such redevelopment). 5.5.2 In the first instance, vehicular access will be provided to the overall development site through the improved Gardeners Lane. Ultimately the future distributor road will also provide access when it is constructed along all of its length in association with future development. 5.5.3 As a consequence of the proposed development, the local highway network will be improved substantially by the provision of a dual carriageway section of road between Lezayre Road and the new roundabout along Gardeners Lane, and sections of the distributor road leading to the east to serve Areas 2 and 3, and to the west to serve Area 4. The section of distributor road leading to the east will ultimately provide for a connection
through to Station Road upon the consequent development of land (outwith the applicants ownership) at Poyldooey and Ballachrink. The formation of the distributor road to the west of the roundabout will provide, consequent to the bridging of the Auldyn River, development of further land to the west. The land to the west is under the control of the applicants. 5.5.4 The application proposals entail no change to the prospects for retaining the existing informal footpath along the former railway line, and in no way affects the prospects for the formal designation of that route as a public footpath. Car parking provision has been made to exceed the minimum standards set out in the Isle of Man Planning Scheme (Development Plan) Order 1982. 5.5.5 The applicants' consultants, Bryan G. Hall, Consulting Civil and Transportation Planning Engineers (BGH), have carried out a traffic assessment of the effects of the proposed development upon the Gardeners Lane/Lezayre Road junction. As the present time, that junction serves some 210 dwellings, plus the associated industrial uses on the west side of Gardeners Lane. In the morning peak the junction has a ratio of flow to capacity (RFC) of 0.27 , notwithstanding the fact that Gardeners Lane is used both by commercial traffic visiting the existing commercial premises, and by parents dropping off their children to attend Ramsey Grammar School. BGH have carried out an assessment on the assumption that Areas 2,3 and 4 are developed in their entirety for housing, and have assumed a total of some 231 dwellings. Taken with existing flows, this will have the effect of changing the RFC at the morning peak at the Gardeners Lane/ Lezayre Road junction to 0.52 , significantly below the recognised threshold capacity of 0.85 . This analysis has been accepted by the Department of Transport Highways Division. Whilst it is acknowledged that this assessment has not specifically assessed the traffic generation effects of the nursery school, public house, and two shop units, it is not considered that the effects of these developments on their own, substituting in part for assessed residential use, will affect materially the safe operation of the existing Lezayre Road/ Gardeners Lane junction.
5.6.1 At present, Areas 2 and 3 drain towards the Sulby River whilst Area 4 drains towards the Auldyn River. It is intended that following development this pattern of disposal will be retained. 5.6.2 In respect of Areas 2 and 3, in association with the flood protection measures (see below) a surface water attenuation feature, with an area of some 1540 square metres, and a storage volume of 1500 cubic metres is proposed to be located within the northern part of Area 3. Surface water from Areas 2 and 3 will drain by gravity via underground systems to the
balancing pond. The invert level of the balancing pond outlet is 3.36 metres AOD and will be connected by an underground pipe to an outfall into the Sulby River at an outfall level of 3.2 metres AOD. 5.6.3 In that section of the surface water drain between the balancing pond and the river outfall a 'Tideflex' check valve will be incorporated to prevent back flow from the river in flood conditions. As noted above, the maximum flood water level (occurring in times of astronomical high tides) in the Sulby River and the Auldyn River is given at 5.75 metres AOD. The combined effect of the flood bank (see below) and the check valve will prevent floodwater entering the site. The surface water-balancing pond will detain surface water until water levels of the Sulby River reduce sufficiently to allow hydraulic gradient to exit waters from the balancing pond. 5.6.4 The capacity of the surface water system in respect of Areas 2 and 3 has been tested at $5,10,50$ and 100 -year return periods. In the worst case, at a 100 -year return storm event there could be some localized surcharging of manholes within the surface water system although any minor flooding would be wholly contained on the road surface between kerbs. and would not affect any residential properties. 5.6.5 In respect of Area 4, it is proposed that surface water will drain directly via a new surface water system into the Auldyn River. Whilst the outfall into the Auldyn River is at 5.52 metres, below the maximum flood level of 5.75 metres, the drainage system will have sufficient capacity to cope with the short term overload conditions and will thus continue to operate effectively under surcharged conditions.
5.7.1 As noted in the WRDF at paragraph 15.1, a study undertaken by Bullen Consultants (Strategic Study of the Sulby River for the Department of Transport (November 2002)) concluded that under extreme worst case conditions, the water level in the Sulby River (and the Auldyn River) adjacent to the application sites could rise to a level of 5.75 metres AOD. Such a flood event would only arise during a combination of astronomical high tides, atmospheric surges, an adverse wind direction and wave action. On average this event is only probable once in 200 years. New housing should be built in a way that protects it from flooding at the level cited above. Area 2 and Area 4 lie above this level, and therefore give rise to no issue in respect of potential flood effect. It is also important to note that no part of Areas 2,3 or 4 would be affected by flooding from the River Sulby alone; the only circumstance of flood risk arises from tidal conditions. The figure of 5.75 m AOD is now a confirmed figure, when the initial design work on the site was being undertaken a figure of
5.9 m AOD was provided to Heritage Homes Ltd's consultants and this latter figure has been used in the design proposals described below (which implies an additional element of safety margin over and above the now confirmed figure). 5.7.2 The major part of Area 3 lies, at present, at a level below 5.9 metres AOD, and as a consequence, without protective measures, that part of the site could not be developed without the incorporation of specific measures. It is intended to develop a floodwall or earth bank of varying widths, to a height of 5.9 m AOD along the western side (adjacent to the proposed footpath aligned parallel to Gardeners Lane) along the northern side (to the common boundary with the Poyldooey Nature Reserve), and along the eastern side of Area 3, all to tie back to existing ground levels at or in excess of 5.9 metres. 5.7.3 The location and appearance of the bank is shown on the submitted planning application drawings. The detailed design of the flood protection measure will ensure that it is impermeable to water penetration in flood conditions. The effect of the construction of the flood bank will be to ensure that in worse case flood conditions, water from the Sulby River does not enter any part of Area 3. 5.7.4 The development of Area 3 through the formation of a flood barrier will have an effect upon the hydraulic capacity of the Sulby River Catchment. The worst-case flood event would be as set out in 5.7.1. above, and it must therefore follow that if the site was developed, that the lost capacity will have to be accommodated elsewhere within the catchment. Given the extent of the catchment, and the circumstance in which the worst case could arise in respect of tidal conditions, the effect on the balance of the catchment would be negligible.
5.8.1 The only element of development that will have a direct effect upon the Poyldooey Nature Reserve will be the new section of surface water drain that will extend from the balancing pond in Area 3 to the Sulby River outfall. Agreement has been reached with the site owners - the Ramsey Town Commissioners - that the drain will be constructed within a narrow ( 10 metre) working corridor with consequent minimum disruption to the existing features within the Reserve. 5.8.2 As noted above, whilst all of the existing hedgerows within the site cannot be retained (a fact acknowledged in the WROF) substantial sections of existing hedgerows, including the virtual entire length of that section on the east side of Gardeners Lane north of the distributor road, have been retained.
5.8.3 No part of the existing salt marsh area will be affected by development (save in respect of the construction of the outfall sewer as noted above). The surface water drainage arrangements proposed - a contained system with ultimate disposal to existing rivers, with on site storage - will be constructed to ensure that there will be no consequential hydrological effect upon the salt marsh, and at all stages of the development agreed best management practices will be implemented to ensure no adverse effects on the existing ground water regime in relation to the ecology of the salt marshes. Such practices could be subject to an appropriate planning condition. 5.8.4 In conceptual terms, the construction of the flood bank around the northern flank of Area 3 might be thought to have some effect upon both the rate and quantum of ground water flows across Areas 2 and 3 and into the salt marsh, but it is considered that any interruption or change to any such event would be likely to be negligible for the following reasons. First, the essential quality of the salt marsh is as a consequence of saline conditions, directly related by the tidal flow of seawater into the Sulby River. Whilst fresh and ground water conditions may contribute to the condition, the saline conditions are more likely to be affected by the Sulby River as opposed to ground water flows. Second, in any event, the extent of existing ground water flows towards the salt marsh area would be likely to be limited following the construction of development at Lezayre Park and the former railway, in that these constructions would have restricted both the extent and rate of any available ground water flows. Third, it is known (see below) that there are areas of peat within the site. There is no strong evidence of ponding or localized wet areas within Area 3, and in the event that there were ground water flows of any significance, water would be likely to accumulate initially in areas of peat before passing north towards the salt marsh. Fourth, the construction of the flood bank will in practice isolate the salt marsh from the land to the south, in that the need for an impervious bank to prevent possible flood incursion will also inhibit any ground water flows from the south. Thus the formation of the bank will have the effect of protecting the salt marsh from deterioration in quality through additional ground water flows. 5.8.5 In respect of the possible effect upon the Poyldooey Nature Reserve, there are certain issues (noted above) relating to ecological matters on Areas 2, 3 and 4. The WRDF acknowledges explicitly that the existing ecology of the area will be affected by the development proposed, but identifies specific criteria that should be applied to ensure that any effects are limited as far as practicable. Heritage Homes Ltd agree with these criteria, but also accept that subject to evidence of the presence of protected species they are willing to undertake appropriate ecological surveys in relation to how the effects of the proposed development upon such species should be managed and phased. The need for such surveys would only arise if protected species are found on site and the nature of the
surveys would require to be agreed with the Department. This issue could be dealt with by condition attached to the planning permissions. 5.9 The following matters relate to ancillary issues, and as with the core issues, are considered separately. 5.10 In respect of archaeology, there is no evidence that the site has either been designated or identified in any respect as a site of particular or potential archeological interest. In that light, Heritage Homes Ltd. do not consider that there might be any argument that all or part of the site should not be brought forward for development. Heritage Homes Ltd. acknowledge that it would, however, be appropriate to incorporate a standard condition relating to providing for access for recording should, in the course of development, any features of archaeological interest be identified. 5.11 Whilst not a matter of directly related to planning considerations, the issue of ground conditions was raised as part of the WRDF consultation. Detailed site investigation within the application sites remains to be undertaken, but it is acknowledged that it is likely that there is peat land within part or parts of the application sites, and to deal with that, it is proposed to utilised short pile construction similar to that used in Balleigh Park in Ramsey. In any event, the question of building foundation is a matter for building control, and not a matter for planning permission. 5.12 The issue of self-built plots in Area 3 was raised as part of the consultation on WRDF. It is Heritage Homes Ltd. intention to sell some of these plots off on the basis of a legal agreement that requires that purchasers will be required to complete development within three years of purchase of the development plots. If purchasers failed to complete the development, they will be in breach of the agreement and ownership of the site will revert to the applicants. As noted at paragraph 3.9 above, the Department will self evidently retain control of development on Area 3 through the grant or refusal of planning permissions for individual plots, in a manner that is in practice no different to the type of control that would obtain if the area was to be developed by a single developer, in that approval for dwelling design and materials would need to be obtained in advance of development, and appropriate conditions relating to associated matters including landscaping, fencing and completion, could be imposed by the Department. 5.13 The issue of adoption of sewers was also raised in the consultation on the WRDF. As with ground conditions this is not a matter that directly relates to planning permission. It is intended that the sewers will be adopted by the Ramsey Town Commissioners, as local drainage authority.
5.14 The issue of First Time Buyers was not expressly raised as an issue in consultation, but is referred to in the WRDF. Following discussion, the Department has confirmed to Heritage Homes Ltd. that some 5 dwellings on the sites should be made available to First Time Buyers. These dwellings will be located within Area 2 and are identified on the site plan. The specific mechanisms by which that proportion of the development will be made available will be subject to separate and detailed agreement with the Department.
6.1 Land east and west of Gardeners Lane is identified for development in the Development Plan. The Ramsey Local Plan is reasonably up to date, having been operational from late 1998. The allocation of the land for development was brought forward from the 1982 Development Plan. Although the Ramsey Local Plan will be reviewed in due course as part of the intended new Strategic/ Area Plan approach, the existing plan will form the basis of development for the next 2-3 years. 6.2 In any event, the appropriateness of the allocations has recently been considered in the context of the Consultation Draft of the West Ramsey Development Framework (WRDF). The WRDF has confirmed that the land - which it describes as Area 2, 3 and 4 - remains appropriate for development. The type and scale of development proposed in respect of each part of the application sites is consistent with the WRDF. 6.3 The existing value of the sites is limited. Whilst the sites are greenfield - in that they have not previously been developed - their use for agriculture (the historic land use) is no longer viable. 6.4 Development of the application sites will bring forward important elements of transport and service infrastructure, but will not give rise to any adverse effect in respect of traffic, ecological or landscape effects. In addition, the proposed development will protect the informal footpath along the former railway to the south, and provide valuable footpath links along the Auldyn River and through the site, leading towards the Poylidooey Nature Reserve. 6.5 The specific arrangement of development on the application sites will provide for the retention of the major part of existing hedgerows within the site and the main groups of important trees. In addition, the development will provide new and enhanced elements of landscape structure, particularly associated with the widened Gardeners Lane and the new distributor road. The development will provide amenity open space and children's play space to meet required standards. 6.6 The development will provide a range of housing to meet the spectrum of local needs in terms of spatial and economic requirements, and will make available dwellings for First Time Buyers to meet the stated requirements of the Department.
6.7 The form of development proposed will reflect substantially the existing suburban qualities of the locality, in terms of density (the density of development proposed will however be higher than that existing adjacent), scale, landscape structure (although with greater emphasis than that existing on retained and new landscape structure) and road arrangements. 6.8 Development of land east of Gardeners Lane will bring forward local retail and community facilities to serve both the new development proposed and the existing residential and commercial development in the locality. 6.9 There are no sustainable objections to the development of the application sites, subject to appropriate conditions.
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