Erection of new four storey apartment building (class 3.4) with ground floor retail space (class 1.1)

Town and Country Planning Act (1999)

development in Conservation Areas

Environment Policy 35

Isle of Man Strategic Plan 2016

Environment Policy 35: Within Conservation Areas, the Department will permit only development which would preserve or enhance the character or appearance of the Area, and will ensure that the special features contributing to the character and quality are protected against inappropriate development. 7.30 Development adjacent to Conservation Areas 7.30.1 It is often the case that important views into and out of a Conservation Area can contribute significantly to its character. It is necessary to assess the impact any development adjacent to conservation areas may have on such views.

Strategic Policy 1

development should be located to make best use of previously developed land

Strategic Policy 1: Development should make the best use of resources by: (a) optimising the use of previously developed land, redundant buildings, unused and under -used land and buildings, and re - using scarce indigenous building materials; (b) ensuring efficient use of sites, taking into account the needs for access, landscaping, open space (1) and amenity standards; and (c) being located so as to utilise existing and planned infrastructure, facilities and services. 4.2.2 In pursuance of (c) abo ve, the Department will, when formulating its programme for the preparation of new Area Plans, have particular regard to: (a) the availability of mains drainage connected to IRIS or other mains systems; (b) securing the future viability of rural primary schools; (c) the public investment in the Island's highway, bus, railway and tramway networks; (d) the provision and availability of water; and (e) community facilities. 4.3 Environment 4.3.1

Strategic Policy 2

focuses new development in existing settlements

Strategic Policy 2: New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(2) of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3. (1) Open Space is defined in Appendix 1. (2) Sustainable Urban Extensions are defined in Appendix 1 4.3.2 Appendix 3 to the Plan identifies the towns and villages, and also explains why the Department has rejected the idea of a new settlement, which was mooted in the Consultation Draft published in May 2000. 4.3.3 Each of our towns and villages has an ind ividual character arising not only from its geographical position and existing fabric, but also from its historical, cultural, and social background. This character should be protected and enhanced. Accordingly:

Strategic Policy 5

development must be well designed

Strategic Policy 5: New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases the Department will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies. 4.4 Economy 4.4.1 The Spatial Strategy identifies the Major Employment Areas around the Island. While the majority of business and employment is focused around the Douglas Metropolitan Area, there are other major employment areas at Castletown, the Airport/Freeport, Peel, Ramsey and Jurby. The Department considers the distribution of employment areas provides a spread of employment opportunities around the Island. While recognising the opportunities for small scale local employment within existing centres it is considered new employment should, in the main, be concentrated within existing settlements or those major employment areas referred to in the Island Spatial Strategy and illustrated on the Key Diagram. Existing Local and new Area Plans will provide detailed boundar ies for these areas. From time to time Government may judge it appropriate to offer financial incentives to encourage economic activity or investment in particular parts of the Island.

Strategic Policy 9

new retail to towns and villages

Strategic Policy 9: All new retail development (excepting neighbourhood s hops and those instances identified in Business Policy 5) and all new office development (excepting corporate headquarters suitable for a business park (1) location) must be sited within the town and village centres on land zoned for these purposes in Area Plans, whilst taking into consideration Business Policies 7 and 8. 4.4.7 The definition of Corporate Headquarters includes offices for those companies using the new information technologies and/or who service other business park users (but specifical ly excludes financial and professional services to visiting members of the public including banks, building societies, estate agencies and betting offices). 4.5 Transport and Communications 4.5.1 There is a direct link between the location of new devel opment, its effect on the transport network and the provision of a more integrated transport network. Accordingly:

Strategic Policy 10

development should promote integrated journeys

Strategic Policy 10: New development should be located and designed such as to promote a more integrated transport network with the aim to: (a) minimise journeys, especially by private car; (b) make best use of public transport; (c) not adversely affect highway safety for all users, and (d) encourage pedestrian movement (1) Business Park is defined in Appendix 1 4.6 Social 4.6.1 The provision of an adequate supply of housing to meet the needs of the wider community is essential; this is in addition to the need to replace existing substandard or poor quality dwellings. Therefore;

Spatial Policy 2

development outside Douglas will be concentrated on Service Centres

Strategic Policy 2: New development will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions(2) of these towns and villages. Development will be permitted in the countryside only in the exceptional circumstances identified in paragraph 6.3. (1) Open Space is defined in Appendix 1. (2) Sustainable Urban Extensions are defined in Appendix 1 4.3.2 Appendix 3 to the Plan identifies the towns and villages, and also explains why the Department has rejected the idea of a new settlement, which was mooted in the Consultation Draft published in May 2000. 4.3.3 Each of our towns and villages has an ind ividual character arising not only from its geographical position and existing fabric, but also from its historical, cultural, and social background. This character should be protected and enhanced. Accordingly:

Spatial Policy 5

new development will be in defined settlements only

Strategic Policy 5: New development, including individual buildings, should be designed so as to make a positive contribution to the environment of the Island. In appropriate cases the Department will require planning applications to be supported by a Design Statement which will be required to take account of the Strategic Aim and Policies. 4.4 Economy 4.4.1 The Spatial Strategy identifies the Major Employment Areas around the Island. While the majority of business and employment is focused around the Douglas Metropolitan Area, there are other major employment areas at Castletown, the Airport/Freeport, Peel, Ramsey and Jurby. The Department considers the distribution of employment areas provides a spread of employment opportunities around the Island. While recognising the opportunities for small scale local employment within existing centres it is considered new employment should, in the main, be concentrated within existing settlements or those major employment areas referred to in the Island Spatial Strategy and illustrated on the Key Diagram. Existing Local and new Area Plans will provide detailed boundar ies for these areas. From time to time Government may judge it appropriate to offer financial incentives to encourage economic activity or investment in particular parts of the Island.

General Policy 2

detailed 'development control' considerations

General Policy 2: Development which is in accordance with the land-use zoning and proposals in the appropriate Area Plan and with other policies of this Strategic Plan will normally be permitted, provided that the development: (a) is in accordance with the design brief in the Area Plan where there is such a brief; (b) respects the site and surroundings in terms of the siting, layout, scale, form, design and landscaping of buildings and the spaces around them; (c) does not affect adversely the character of the surrounding landscape or townscape; (d) does not adversely affect the protected wildlife or locally important habitats on the site or adjacent land, including water courses; (e) does not affect adversely public views of the sea; (f) incorporates where possible existing topography and landscape features, particularly trees and sod banks; (g) does not affect adversely the amenity of local residents or the character of the locality; (h) provides satisfactory amenity standards in itself, including where appropriate safe and convenient access for all highway users, together with adequate parking, servicing and manoeuvring space; (i) does not have an unacceptable effect on road safety or traffic flows on the local highways; (j) can be provided with all necessary services; (k) does not prejudice the use or development of adjoining land in accordance with the appropriate Area Plan; (l) is not on contaminated land or subject to unreasonable risk of erosion or flooding; (m) takes account of community and personal safety and security in the design of buildings and the spaces around them; and (n) is designed having due regard to best practice in reducing energy consumption. 6.3 Development outside of areas zoned for development

General Policy 4

Section 13 agreements

General Policy 4: Where appropriate the Department will enter into Agreements under section 13 of the 1999 Town and Country Planning Act which may: (a) restrict the use of land; (b) require land to be used in a particular way; (c) restrict the operations which may be carried out in, on, under or over land; (1) Previously developed land is defined in Appendix 1 (d) require operations or activities to be carried out in, on, under or over land or; (e) require payments to be made to the Department either in a single sum or periodically, in particular as commuted sums for open space or parking provision, or other social or cultural provision, including public art, which is necessary and directly associated with the development proposed. 6.4.2 Planning Agreements will not be used to support the approval of proposals which are not in accordance with the Aim, Objectives and Policies of the Plan. To date, Planning Agreements have only been used in a limited number of cases. Supplementary Guidance will be prepared for Agreements under Section 13 of the 1999 Town and Country Planning Act, t o be read in conjunction with the Strategic Plan. This will set out the principles and practice of the Department to ensure consistency and to avoid unnecessary delay to the planning and development system. 6.5 Enforcement 6.5.1 Under Part 4 of the Town and Country Planning Act 1999, the Department has duties in respect of breaches of planning control. In any case, the objectives of this Plan would be thwarted without an effective development control system, part of which is, of course, enforcement against breaches of control. 6.5.2 The Department will rectify breaches of control firstly by negotiation, but where this fails and (a) a regularising application is unsuccessful; and (b) the breach is clearly contrary to any of the policies of this Plan; the Department will consider the commencement of enforcement action in accordance with Part 4 of and Schedule 4 to the 1999 Town and Country Planning Act.

Environment Policy 42

new development should be designed to take into account the character and identity of the area

pment. 8.13.2 The extent of formal open space with in settlement boundaries in the South is identified on the Proposals Map (Map 3) and Inset Maps (Maps 4-7). The Isle of Man Strategic Plan (Environment Policy 42) seeks to protect these open spaces and indicates that: 8.13.3 "Inappropriate backland development, and the removal of open or green spaces which contribute to the visual amenity and sense of place of a partic ular area will not be permitted.''

Business Policy 1

growth of employment opportunities

Business Policy 1: The growth of employment opportunities throughout the Island will be encouraged provided that development proposals accord with the policies of this Plan. 9.1.3 This chapter concent rates on the land use implications of business activity, including industry, storage and distribution, office and commercial development, retailing and tourism. 9.1.4 In respect of employment land availability, the Department has undertaken and published an Employment Land Availability Study (1). A summary of this is included in Appendix 9. Across the Island there are some 118 hectares of land allocated for industrial development. Much of this is concentrated around Ballasalla and the Airport. There is, however, a spread of land available across the Island to support employment and regeneration opportunities in each area. Such land will be important to support the regeneration of the Service Centres and the Gateway and Employment role of the Airport area. 9.1.5 The Douglas area has seen by far the bulk of the industrial land take up in recent decades and much of the land allocated for such purposes has been taken up. This is why the Department has resolved to proceed with a Development Order for the development of some 20 hectares of employment land to the south of Cooil Road. A recent report on the take up of industrial land in the Douglas area indicates that it has been faster than anticipated and at current rates that all the land will be required by 2015. While the situation will be subject to detailed assessment in the preparation of the Plan for the East, the Department is satisfied that the release of additional land is both necessary and appropriate at this stage. 9.1.6 The Department has also reviewed planning permissions for office development. The majority of these are focused in the Douglas area. Take up has been low in recent years with the exception of certain relocations to corporate headquarters, such as Skandia. There are a number o f sites still available for new office development, in addition to the existing stock. Of note is the recent trend for sites with office consents to subsequently secure planning permission for residential use. The most notable example being the final pha se of the Villiers development, which now has a residential permission in addition to its partly - implemented office consent. 9.1.7 The following information has been extracted from the Review of Economic Strategy (Treasury 2003) which formed part of the background to the Economic Strategy 2004 approved by Tynwald in October that year. (1) Employment Land Availability Study DLGE 2007 9.1.8 The Isle of Man has enjoyed unprecedented economic success in the last ten years. Over this period annual gross domestic product, or GDP (the value of the economy' s output of all goods and services), has more than doubled in real terms (both absolute and per capita) such that from a deficit of around one quarter, per capita GDP in the Isle of Man now exceeds that of the UK by 7% and the average for the European Union (EU 15) by 10%. 9.1.9 The period 1993 - 2000 saw the economy not only expanding but doing so at an accelerating rate, before slowing in 2000/01. Since 2001 the economy has continued to grow at around 5% per annum (the latest national income accounts revealed growth of 5.9% in 2002/03), meaning that, after the recession in the early 1980's the Isle of Man economy has recorded economic growth in each of the last twenty years. 9.1.10 This economic performance has been led by the financial and related se rvices sectors. The finance industry grew by over 80% between 1996 and 2001 alone. But the table below illustrates that probably all areas of Manx economy are today generating more income in real terms than a decade ago, even it the relative importance o f some, most noticeably manufacturing, has declined. Table One - Sectoral Contributions to National Income 1992/93 v 2000/01 (at 2000/01 prices) Contributions to National Income (£) Real Increase in income generated (%) 1992/93 % 2000/01 % Manufacturing 72.0 11 76.7 6 6.5 Finance 229.7 35 505.4 41 120.0 Tourism 41.0 6 67.7 6 65.1 Agriculture/Fishing 11.7 2 15.8 1 35.0 Construction 46.7 7 89.6 7 91.9 Professional Services 96.7 15 186.1 15 92.4 Utilities, Distribution and Miscellaneous Services 133.1 20 223.8 18 68.1 Pubic Administration 34.6 5 53.6 4 54.9 Total 665.5 100 1,218.7 100 83.1 9.1.11 National income data aside, the clearest indication of the economic success enjoyed by the Island in recent times comes from the labour market. Census results show that the workforce increased from 33,189 in 1991 to 39,685 by 2001, an increase almost identical to that in the total resident population over the period. But the number seeking emp loyment but who were unemployed at the time halved from 1,360 to 635. 9.1.12 Changes in the underlying structure of the economy reflected in the national income accounts are further depicted in the Census statistics below showing the distribution of labour between the different sectors of the economy. Table Two - Employment by Sector 1991 v 1996 1991 1996 2001 No. % No. % No. % Agriculture and Fishing 1,240 3.9 938 2.8 543 1.4 Manufacturing 3,348 10.5 3,562 10.6 3,185 8.2 Construction 3,404 10.7 3,372 10.0 2,512 6.4 Utilities1 513 1.6 462 1.4 515 1.3 Transport and Communications 2,437 7.7 2,688 8.0 2,970 7.6 Wholesaling and Retailing 3,844 12.1 3,692 11.0 4,372 11.2 Finance 4,353 13.7 5,942 17.7 8,959 22.9 ICT2 n.a n.a n.a n.a 361 0.9 Professional Services 5,438 17.1 6,081 18.1 7,296 18.7 Tourist Accommodation 856 2.7 765 2.3 743 1.9 Entertainment and Catering 1,403 4.4 1,156 3.4 2,116 5.4 Miscellaneous Services 2,849 9.0 2,768 8.2 2,373 6.1 Public Administration 2,144 6.7 2,146 6.4 3,105 8.0 Total 31,829 100.0 33,5773 100.0 39,050 100.0 Notes: 1 Electricity, gas and water 2 Not separated out from other sectors until 2001 3 Includes 5 where occupation not recorded 9.2 Industry and Storage and Distribution 9.2.1 The nature of industrial activity on the Island changed very considerably during the last century. The previously dominant primary industries of fishing and agriculture now contribute only 1% to the Gross Domestic Product (GDP) and provide only 1.4% of our total employment, whereas manufacturing contributes 6% to the GDP and provides 8.2% of our employment, and the construction industry contributes 6% to the GDP and provides 6.4% of our employment. Storage and distribution has also become a more important activity, particularly in terms of the demands it makes on land, buildings, and access requirements. 9.2.2 Most of the Island's industry is located close to major transportation links, particularly in the case of Douglas, Braddan and Ballasalla, which all have convenient access to Ronaldsway airport and Douglas harbour. Ramsey and Peel harbours are used for the importation and exportation of large scale good s (fuel, building supplies etc). All of these are conveniently accessible to significant pools of labour. In order to minimise excessive transportation of goods and travel for employees, and to promote sustainable development, much of the Island's future industrial development should continue to be concentrated in these locations, and appropriate areas of land should be made available for such uses in the Area Plans for these parts of the Island. It will also be appropriate, when formulating Area Plans for our smaller settlements, to make provision for the continued operation of small -scale family businesses, particu

Business Policy 9

support for retail in existing defined areas

Business Policy 9: The Department will support new retail provision in existing retail areas at a scale appropriate to the existing area and which will not have an adverse effect on adjacent retail areas. Major retail development proposals will require to be supported by a Retail Impact Assessment(1). (1) Retail Impact Assessment is defined in Appendix1.

Community Policy 7

designed to prevent criminal and antisocial behaviour

Community Policy 7: The design of new development and the extension and refurbishment of existing buildings and development must, as far as is reasonably practical, pay due regard to existing best practice so as to help prevent criminal and anti-social behaviour. 10.12.2 The Isle of Man Constabulary has suggested that neighbourhood police stations, where the public can meet police officers, are needed to improve community safety. In the majority of cases these will need to be provided within existin g communities as opportunities arise. Consideration should be given to incorporating such facilities in larger new developments in association with other community facilities.

Housing Policy 4

new housing will be located primarily within the existing towns and villages

Housing Policy 4: New housing will be located primarily within our existing towns and villages, or, where appropriate, in sustainable urban extensions (1) of these towns and villages where identified in adopted Area Plans: otherwise new housing will be permitted in the countryside only in the following exceptional circumstances: (a) essential housing for agricultural workers in accordance with Housing Policies 7, 8, 9 and 10; (b) conversion of redundant rural buildings in accordance with Housing Policy 11; and (c) the replacement of existing rural dwellings and abandoned dwellings in accordance with Housing Policies 12, 13 and 14. 8.5.6 The anticipated increase in the total number of dwellings on the Island over the Plan period is approximately 14%. By administering the programme of Area Plan preparation, the Department will ensure that there is sufficient land zoned for residential development to meet the overall housing requirement figure required by Housing Policy 1. The Department has resolved to prepare under the provisions of the Town and Country Planning Act 1999 four Area Plans which will concentrate upon larger areas of the Island. These will focus on the North, West, East and South of the Island and correspond with those areas discussed at paragraph 5.9 of the Spatial Strategy Chapter. 8.6 Affordable Housing 8.6.1 The Department is concerned about the increasing difficulties of securing the provision of affordable housing across the Island. The Department can, and does as a Housing Authority, intervene financially to provide financial support to local Authorities; financial support to prospective owner occupiers (through the House Purchase Assistance Scheme 2002) and by direct provision of new houses to rent. The provision of affordable housin g is a material consideration in the preparation of the development plan. In the current situation the Department considers that, to secure an adequate provision of affordable housing, it is appropriate to require that any area of land identified for hous ing purposes should include a contribution towards the provision of affordable housing. 8.6.2 There are currently around 1,584 (as at 31 st March 2007) households on the General Housing Waiting List. In addition, there are some 690 (as at 31 st March 2007) households registered with the Department under the House Purchase Assistance Scheme (HPAS). This indicates a total current need of some 2,274 households for affordable housing. (1) Sustainable Urban Extensions are defined in Appendix 1 8.6.3 In the current circumstances the Department considers that approximately 25 % of new housing provision should take the form of affordable housing. In assessing the appropriate percentage in each instance, the Department will have regard to the fact that the figure is a target over the Plan Period as a whole; to evidence of local housing need; to the nature of the land and viability of the scheme; and to the nature of existing adjacent housing. The 25% provision will be monitored and reviewed as part of any review of the Strategic Plan.

Transport Policy 1

best located close to existing transport links

Transport Policy 1: New development should, where possible, be located close to existing public transport facilities and routes, including pedestrian, cycle and rail routes.

Transport Policy 4

safe and appropriate provisions for journeys

Transport Policy 4: The new and existing highways which serve any n ew development must be designed so as to be capable of accommodating the vehicle and pedestrian journeys generated by that development in a safe and appropriate manner, and in accordance with the environmental objectives of this plan. 11.3.2 Notwithstanding policies within this plan which encourage travel by means other than private car it is anticipated that the number of vehicles using the Island's roads will continue to increase. This increase in demand is likely to lead to a greater need for road impro vements in order that travel can take place in a safe, effective, and environmentally acceptable manner. The Department of Transport will continue to assess the need for such improvements to public highways and undertake works where appropriate, with much of the improvement within existing roads carried out under the provisions of the Town and Country Planning (Permitted Development) Order2005. The need for improvements to the Island's highway network must be balanced against the environmental objectives of this plan.

Transport Policy 7

parking standards

Transport Policy 7: The Department will require that in all new development, parking provision must be in accordance with the Department's current standards. The current standards are set out in Appendix 7. 11.5.4 New development can have a significant impact in terms of the traffic generated by it and the impact on the various modes of travel. The Department considers that proposals which are likely to be significant traffic generators should be accompanied by a Transport Assessment(1) which should look at all modes of transport including access by public transport, cycling and on foot.

Infrastructure Policy 5

methods for water conservation

, if it can be demonstrated that development there would not result in an incursion into the countryside. However there is no corresponding proposal for residential areas. Proposed Change 75 (in PIP5) now indicates that appropriate colour washes should be applied to the Proposals Map, to show the Mount Murray and Braddan Hills areas as 'Predominantly Residential'; and the Snugborough Estate as 'Industrial'. I agree with this. I also recommend that the whole of the waste management area at Richmond Hill should be similarly delineated and washed over as a site for 'Special Industry' (as defined in paragraph 9.2.3 of the Strategic Plan). CHAPTER 4 - LANDSCAPE Landscape Character Areas and Areas of High Landscape Value 25 Chapter 4 of the draft Area Plan is headed 'Landscape - Character and Appearance'. It draws on a Landscape Character Assessment Report which was prepared for the Government by consultants in 2005. The report describes the qualities of a series of Landscape Character Areas, and identifies landscape features that are worthy of protection. It excludes consideration of the urban areas of Douglas and Onchan. 26 Landscape Proposal 1 of the Area Plan states that the broad landscape strategies and key views for each Character Area are to be regarded as policy statements on matters of landscape in the East. Applicants for planning approval must demonstrate that consideration has been given to these strategies and key views. Twenty different Character Areas are identified. The key strategy for each of them is to 'conserve' (or 'conserve and enhance') the 'character, quality and distinctiveness' of the area; and of certain specified landscape features. During the inquiry, a number of objectors to proposed land allocations argued that this policy of landscape conservation should outweigh other considerations which might tell in favour of development. In my view, if landscape policy fails to distinguish between areas of outstanding beauty or cultural interest on the one hand, and less sensitive areas of countryside on the other, it may become increasingly difficult to find sites for essential development. 27 The approach set out in the Area Plan is intended to replace a landscape policy which has been in place since 1982, and is encapsulated in Environment Policy 2 of the present Strategic Plan. That policy identifies Areas of High Landscape or Coastal Value and Scenic Significance (AHLV). Within each AHLV the protection of the character of the landscape is normally the most important consideration for development control purposes. By implication, outside of AHLVs, other factors can be given relatively greater importance. I consider this to be a useful policy tool, in so far as it identifies those areas which can best absorb necessary development without harming the most sensitive landscapes. A similar policy applies in England, where the protection of the landscape is given priority in National Parks and Areas of Outstanding Natural Beauty. The general extent of AHLVs is shown in the Strategic Plan's Key Diagram. 28 Some necessary development will inevitably change and possibly detract from the character of the landscape. Examples might include the extraction and processing of minerals, the management of waste, the generation and transmission of electricity, the construction of roads, or the erection of factories and houses. In my view, it is important that landscape policy should provide guidance as to where such development might best be absorbed into the landscape with minimum harm. 29 Accordingly, it seems to me that consideration should be given to the continued designation of Areas of High Landscape Value in the Area Plan, and that priority should be given to the protection of the landscape in those areas. The Area Plan should define the precise boundaries of the AHLV. ( I note that the rural areas of both Braddan and Onchan are currently covered by a blanket AHLV designation, which may be difficult to justify). I am aware that development control officers find the descriptive material set out for each Landscape Character Area in the draft Area Plan to be useful. I see no reason why the material in question should not be retained in the Area Plan, alongside AHLV. 30 I recommend that consideration be given to the designation, in the Area Plan, of Areas of High Landscape Value, with precise and justified boundaries. Environment Policy 2 of the Strategic Plan would continue to apply within such areas. Effect of Proposed Development on the Landscape North of Douglas and Onchan 31 Miss P Newton and Dr K Kilmurry each referred to the potential impact of proposed development of sites on the northern edge of Douglas and Onchan, referring particularly to the adverse effect of building on the skyline, and the need for an overall scheme of landscaping. I consider it important that development briefs for the sites in question should make provision for the preparation of masterplans which would include comprehensive landscaping schemes. Details of these would

Environment Policy 10

flood risk

irements of the relevant gas supply agency. Flood Risk 63 There was widespread concern about the adequacy of drainage and the risk of flooding, particularly in parts of Braddan, Onchan and Laxey. Environment Policy 10 of the Strategic Plan indicates that where development is proposed on any site where there is a potential risk of flooding, the prospective developer will be required to submit a flood risk assessment, together with details of proposed mitigation measures. This approach is reinforced in Utilities Proposal 6 of the draft Area Plan, which (among other things) requires the incorporation of Sustainable Drainage Systems (SuDS) into new developments, to attenuate the rate of surface water run-off. I consider these policies to be reasonable. Clearly, without adequate mitigation measures, new building should normally be resisted on land which is at serious risk of flooding, or where the proposed development would increase the flood risk elsewhere. 64 In my view, the format of Utilities Proposal 6 could be improved. First, as a Proposal of the Area Plan, I consider that it should be in a bold typeface, to differentiate it from the supporting text. (The same applies to a number of other policies e.g. Transport Policy 2, and Utilities Policies 2 and 5). Second, there appears to be an error of syntax at the start of the second sentence of Utilities Proposal 6, which should perhaps read 'Strategies to achieve this will include …'. Third, the third bullet point of this Proposal introduces SuDS. Subsequent bullet points describe features of SuDS, and are therefore subordinate to the third bullet point. For clarity, I consider that they should be indented. I recommend that the draft Area Plan be modified accordingly. Sewage Treatment 65 There was also some public concern about the adequacy of the sewerage system, both in terms of its capacity to accommodate the effluent from proposed residential development areas, and in terms of the current practice of discharging untreated sewage into the sea. Infrastructure Policy 1 of the Strategic Plan indicates that developments entailing the erection of multiple dwellings should take place only on sites that will ultimately be connected to the IRIS system, which takes sewage to a treatment works at Meary Veg. (IRIS is an acronym for Integration and Recycling of the Island's Sewage). However, as long ago as 2006/7, a review was undertaken to decide whether to continue with the IRIS strategy. This concluded that it would be beneficial to adopt a regional sewage treatment strategy (RSTS) for those settlements that were not already connected to the IRIS system, including Laxey, Baldrine and settlements in the Central Valley. To that extent, Infrastructure Policy 1 of the Strategic Plan is now out of date. 66 I understand that a planning application will soon be submitted for the development of a local sewage treatment facility for Laxey. Feasibility studies for the provision of a similar facility to serve Baldrine are ongoing. A replacement sewage works at Ballagarey, serving part of the Central Valley became operational in 2018. However, capacity limitations mean that planned development in Crosby is likely to have to rely on standalone sewage treatment for the time being, until the existing treatment works is replaced as anticipated in 2022. The Programme for Government (2016-2021) indicates an intention to complete the regional sewage treatment infrastructure within the lifetime of the present administration. 67 It seems to me that these considerations should be taken into account in the allocation and phasing of land for development. I will return to this matter when considering the draft Area Plan's proposals for housing. Electricity Renewable Energy 68 Peel Energy considered that the Area Plan should contain a detailed and specific chapter on renewable energy, providing measurable criteria against which applications for the development of renewable power generating facilities would be assessed. They cited the States of Jersey Island Plan 2011, which includes such material. And they pointed out that a Climate Change Emergency has recently been declared on the Isle of Man; that a Climate Change Bill is soon to be presented to Tynwald; and that there has been strong public support for the Government's Climate Change Mitigation Strategy. They argued that, in failing to provide detailed guidance on renewable power generation, the Area Plan was inconsistent with the Strategic Plan; and that since the Area Plan post-dated the Strategic Plan, its largely negative provisions would prevail. 69 Energy Policy 4 of the Strategic Plan applies to development proposals for renewable energy generated by wind, water, tidal or solar power. It indicates that any such proposals will be judged against that Plan's environmental objectives. Proposals for wind, water or tidal power would need to be supported by an Environmental Impact Assessment. The supporting text indicates that renewable energy schemes will be given similar scrutiny as is gi