The Area Plan for the East Cabinet Office’s response to the comments received on the Modifications Pink Paper (Annexe 2 - Part 1) Cabinet Office 21st September 2020 Submitted via: 1. Response Form Cabinet Office Rec / Mod or Description of Respondent Code Respondent Name 2. Correspondence No. Comment Response (email/letter) Representation or Objection The Board’s main concerns remain as follows: CO has defined all of the Greep Gaps by following field boundaries. In addition there are two additional green gaps between the settlements of Union Mills, Strang 1. The inadequate provision of a green gap between the built up areas of douglas and braddan. There appears to be and Douglas. inconsistency in how the policy is being applied to different areas and the size of the gaps. The extent of all of the gaps has been reviewed. The only change since the 2. The contradictory approach to coalescence and sustainable urban extensions. Modifications is the Laxey and Baldrine Green Gap which has been reduced in size in response to comments on scale. 3. Incursion/elimination of open countryside between Douglas and Braddan and the inconsistent approach being adopted in deciding why it is acceptable for one area of open, productive countryside to be zoned and not another. 4. The zoning of CO does consider that there has been an inconsistent approach. BHLF-AAMW-WTX7-Z Braddan Commissioners Letter M 32 greenfield sites for immediate release, which will discourage what we thought was the primary objective of the Strategic Plan- i.e. sustainable development and, in this area plan, prioritising redevelopment in the towns. CO accepts the findings of the Inspector that even allowing for a high proportion of the units to come from existing sites within the settlements, some other In addition, the board is still also at a loss to understand why the CO is still reluctant to consider rezoning sections of the opportunities are still required. development on Peel Road as residential, and part of the site on the lower part of Vicarage Road as industrial or at least mixed use. CO is content with the extent of the zonings on land south of Vicarage Road and bordering Peel Road. The change to allow the potential release of reserve sites before 2026 is not supported. Noted. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 65 Please see Strategic Reserve Site Release Mechanism - para 12.19. Chapter 4 – Landscape. The Commissioners support the recommendation of the inspector that an element of the old landscape The AHLVCSS areas and other variants do not have clear and precise boundaries nor assessment should be preserved to enable greater weighting to be given to protecting a site that has more landscape value than an available original evidence base as the Inspector has recommended and it would another. This does not seem to be reflected in the proposed modified area plan document and as such we consider this an not be possible to reflect this in the Modified plan as the Insector intended. omission by the CO and that it should be corrected. The previous wording was a more accurate description of what is actually BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form R 5 planned Cabinet Office will therefore follow the landscape 'types' and 'areas' using the Landscape Character Assessment study only - as was followed in the extant Area Plan for the South. M3/4 Support Noted. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 3 Wildlife sites: para 5.11.4 It is suggested that there is the possibility to create a wildlife area alongside the River Dhoo between Cabinet Office support the creation of new wildlife sites and the principle of Braddan Bridge and Snugborough. biodiversity net gain. The Table 6 of the written statement will be updated to reflect BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 4 this suggestion. Addition proposal 4 para 5.15.6 Green Gap: Support Cabinet Office understands the concern expressed but this area is to be retained as However the proposal is not being properly implemented by the failure to designate the area between Port-e-chee meadow and predominantly residential. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 4 Ballafletcher Rd. as a green gap M5 Support Noted. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 5 M11: Partial Support/Objection – Street lighting is a local authority responsibility and it is for the authority to determine if it is Cabinet Office accepts this minor amendment BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 11 appropriate to install lighting in some of the areas listed. In the final bullet point, “Public Lighting should be provided” needs to be changed to: “It is recommended Public Lighting is provided ….. “It is recommended Public Lighting is provided …..Utilities Proposal 2 Table 9 para 8.9.5: The Commissioners would prefer the industrial estate in Union Mills (old Marown Engineering works) to be Noted. However, the time for consideration of the merits or otherwise of this Comment not mixed use including residential/office use. It is suggested the site could be suitable for a retirement/nursing home neither of suggestion has now passed. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form C specific to a which currently exist in Braddan. modification. M17: Partial objection- The Commissioners believe the early release of the land south of the Cooil Road will deter redevelopment The development of land to the south of Cooil Road, needs to be carefully master BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 17 of brownfield or underutilized commercial sites elsewhere on the island and this are should be held back to a later date. planned. M19/M20: Support. In addition the Commissioners would be content for some of the land to be used for other unneighbourly Noted. The descriptions will however remain as set out in the modifications. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 19 activities, such as concrete product production and similar that may use some of the recycled aggregate/other material. M29: Support but Braddan does have a youth club, which is an omission in the table, and also some indoor sports facilities. Table 10 only contains outdoor pitches and play parks. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 29 M25: Object The commissioners contend this will result in a over provision of housing, most likely on green field sites, contrary Prior to the Inquiry Cabinet Office sought to temper the provision made in the draft to the principles of urban regeneration. plan in light of the census findings. The Inspector has reviewed all the evidence and place further sites into strategic Reserve or removed entirely from the plan. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 25 Cabinet Office accepts these figures in relation to M25. 1 Submitted via: 1. Response Form Cabinet Office Rec / Mod or Description of Respondent Code Respondent Name 2. Correspondence No. Comment Response (email/letter) Representation or Objection M27: No objection although given the possibility of a change in way office employees work in future, there may be an Recent events will of course influence the way we - as an Island community - work, overcapacity in office space in towns that could be redeveloped as residential. interact and go about our daily lives. The implications for the Island's planning system and ideas as to how, if at all, it needs to change in order to respond to the sustainable development needs of the Island, in response to the pandemic are only BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 27 just emerging. New approaches may well be needed and this includes looking at the implications for office supply and demand and how we move forward. Additional research and monitoring will no doubt be needed. M26: Object – The previously identified 'reserve sites' should not be able to be brought forward on a speculative basis and determined purely on their merits. They should not be released at any time in the near future. Site BH030 and DBH002, if Please see Strategic Reserve Site Release Mechanism - para 12.19. included in the adopted plan should be a reserve site. If reserve sites are to be released then they should be on the basis of land falling within the existing town boundaries should be Sites BH030 and DBH002 are to remain as general allocated sites in line with the released prior to sites outside those boundaries. Inspector's Report. Site BM006 should be reallocated as mixed use to allow part of the site nearest the existing Kirby trading estate to become an BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 26 extension to the estate. This is a more sustainable site for business use as it is outside the TT course. It would also go hand in Cabinet Office will monitor the extent to which sites are being delivered and where glove with changing the designation of employment land between Braddan Bridge and the Snugborough Trading estate on the these sites are. Peel Road, but now not a good neighbour to the river corridor or the adjacent residential areas, to predominately residential (inc open space/nature/wildlife/amenity area). In terms of considering sites for other purposes, the time for doing so has now passed. M28: The commissioners remain disappointed by this outcome Noted. BHLF-AAMW-WTX7-Z Braddan Commissioners Response Form M 28 The Commissioners would support a delay in publishing the plan to allow for the additional census data etc. to be factored into CO understand the temptation to wait until the next Census but it has to be the plan.